| Original SIF regulation | RD 1007/2023, of 5 December |
|---|---|
| Amendment | RD 254/2025, of 1 April |
| Technical development | Order HAC/1177/2024, of 17 October |
| Latest extension | RD-law 15/2025, of 2 December |
| Date for the self-employed (personal income tax) | 1 July 2027 |
| Date for companies (corporate income tax) | 1 January 2027 |
| Maximum penalty | Up to 50,000 euros (art. 201 bis LGT) |
The questions we get asked the most
These are the 10 questions we receive most often from freelancers in every Verifactu readiness check. The answers are based on the regulation in force as of June 2026 and the practice we see with clients. For your specific case it is always worth confirming with your accountant. This does not replace personalised tax advice.
1. When does Verifactu become mandatory for the self-employed?
On 1 July 2027. That date was set by Royal Decree-law 15/2025, of 2 December, which postponed the original entry into force. For companies (subject to Corporate Income Tax) the obligation arrives earlier, on 1 January 2027, and for the self-employed six months later. Full framework: RD 1007/2023, RD 254/2025, Order HAC/1177/2024, RD-law 15/2025.
2. I am in the SII (Immediate Supply of Information). Do I also have to comply with Verifactu?
No. Parties required to use the SII are excluded from the scope of Verifactu. If you are in the SII because of your turnover (over 6,010,121.04 euros in the previous year), through registration in REDEME, by belonging to a VAT group or by voluntary election, Verifactu does not apply to you. More detail in the SII vs Verifactu comparison.
3. If I issue 10 invoices a year, am I really obliged?
Yes. The obligation has no volume threshold. What matters is being required to issue invoices for your economic activity. A freelancer who bills 10,000 euros a year is just as obliged as one who bills 300,000 euros. The penalty under article 201 bis of the General Tax Law (up to 50,000 euros) does not scale with volume either. It is for non-compliant invoicing software, not for the number of badly issued invoices.
4. I use FacturaPlus. What do I do?
FacturaPlus has been discontinued for years and will have no native Verifactu support. You need to migrate to software validated by the AEAT before 1 July 2027. The official list of authorised software is published on the AEAT electronic office. Holded is one option with native Verifactu and official AEAT Social Collaborator status, but there are alternatives. What matters is checking that it appears on the validated list.
5. VeriFactu or Non-VeriFactu mode? Which suits me?
For most freelancers, VeriFactu (real-time submission to the AEAT) makes sense: it simplifies day-to-day operations, reduces internal retention obligations and gives more confidence in the event of an inspection. Non-VeriFactu mode (no real-time submission, full retention for the legal period) is valid but implies more technical responsibility over traceability. It only makes sense if you have real connectivity constraints or a well-founded reason from your accountant to opt for it.
6. My current software is Excel. Is it valid under Verifactu?
No. Excel does not generate the chained SHA-256 fingerprint or the QR code required by RD 1007/2023. You need to migrate to invoicing software validated by the AEAT before your date (1 July 2027 for self-employed under personal income tax). The change is orderly if you plan it with time. Starting in Q3 2026 gives you margin.
7. I am self-employed under the modules regime. Does Verifactu affect me?
If your activity requires you to issue invoices (regardless of your tax regime), Verifactu applies to you. The objective estimation regime (modules) affects how you calculate your personal income tax, but it does not exempt you from the invoicing obligation. If your activity under modules requires issuing invoices (typically yes when you have business clients), you will enter Verifactu on 1 July 2027.
8. Invoices that come in automatically from Stripe or Shopify, do they also have to be Verifactu?
Yes, any invoice issued after your entry-into-force date (1 July 2027 for self-employed under personal income tax) must comply with Verifactu, whether generated manually or by automatic integration with an external platform. A poorly built Shopify to Holded or Stripe to Holded integration can create invoices that break the fingerprint chain. More technical detail in the post on Verifactu in ecommerce.
9. What about the invoices I issued before my mandatory date?
They do not require retroactive Verifactu. The obligation applies only to invoices issued from the entry-into-force date for your group (1 July 2027 if you are self-employed under personal income tax). Historical invoices are kept under the previous rules. You do have to keep them accessible during the mandatory retention period (typically 4 years plus the statute of limitations) in case of an inspection.
10. I am switching from self-employed to an SL company in 2026. When does Verifactu apply to me?
Your new SL is subject to Corporate Income Tax, so it enters Verifactu on 1 January 2027 (not 1 July, which applies to the self-employed under personal income tax). If the company is set up at the end of 2026, your first SL invoice already in 2027 has to be Verifactu compliant. If you keep billing something as a freelancer in parallel (with your individual tax ID), that flow enters Verifactu on 1 July 2027. Each tax ID is assessed separately.
Practical recommendation if you are self-employed in 2026
- 1Confirm with your accountant whether you are in the SII. If you are, Verifactu does not apply to you and you can stop reading.
- 2Review your current invoicing software. If it is FacturaPlus, Excel, Word or a system not validated by the AEAT, plan a migration to a validated one before Q3 2026 to give yourself margin.
- 3If you already use validated software (Holded, Sage, Anfix, FacturaDirecta or similar), check with your provider that it has native Verifactu and that the plan you pay for includes it.
- 4Decide VeriFactu or Non-VeriFactu mode with your accountant. By default VeriFactu is the simplest option for freelancers.
- 5If you have automatic integrations (Shopify, Stripe, etc. creating invoices in your software), audit that each flow is Verifactu compliant. A bad integration breaks the chain just like bad software does.
If you have a question that is not on this list, ask us by email or call and we will add it to the post so it helps others.
Related reading
Notice: this post summarises the regulation in force as we understand it as of June 2026 and the practice we see with clients. It does not replace personalised tax advice. For your specific case, consult your accountant and check the official list of authorised software on the AEAT electronic office (sede.agenciatributaria.gob.es).
Juan Cantón Rodríguez
Founder and lead developer at Francodesystems. He designs Holded integrations with a focus on Verifactu compliance from day one: a complete SHA-256 fingerprint chain, idempotency under concurrency, validation of mandatory fields. He maintains n8n-nodes-holded.