Companies become mandatory
Corporate-tax payers (Spanish SL, SA, cooperatives and the Spanish subsidiaries of foreign groups) must issue from Verifactu-compliant software (Royal Decree-law 15/2025).
← Invoicing in Spain, in English
Verifactu, explained for foreign companies.
By Juan Cantón Rodríguez · Updated
Spain is making anti-fraud billing software mandatory. If your company invoices under Spanish rules, your billing software has to meet Verifactu by the legal deadline (2027 today). Here is what it means, and how we get you there, in English, without the bureaucracy.
Update 7 Oct 2026 Spain's Ministry of Finance has announced a delay of Verifactu to October 2028. Until it is published in the BOE, the legal dates remain 1 January 2027 (companies) and 1 July 2027 (everyone else).
What Verifactu actually is
Spain's anti-fraud invoicing standard, in plain English
Verifactu is the operating mode of Spain's new billing-software regulation (the Reglamento de sistemas informáticos de facturación). Its goal is simple: make it impossible to alter or delete an invoice after it is issued. Every compliant system has to guarantee that the record cannot be tampered with.
- →Each invoice carries a SHA-256 fingerprint chained to the previous one, so the sequence cannot be broken without detection.
- →Every invoice prints a QR code that lets the recipient (and the tax authority) verify it.
- →In VeriFactu mode, the record is sent to the AEAT (the Spanish tax agency) in real time. In No-VeriFactu mode it is kept under strict tamper-proof retention instead.
Key dates
The deadlines that apply after the latest postponement
Royal Decree-law 15/2025 moved the mandatory dates to 2027 in two phases by legal form. On 5 October 2026 the government announced a further delay to October 2028, but until it is in the BOE these are still the legal dates. B2B e-invoicing follows as a separate obligation.
Everyone else follows
Self-employed individuals under IRPF, non-residents with a permanent establishment in Spain and income-attribution entities enter six months later.
B2B e-invoicing (separate rule)
Royal Decree 238/2026 and Order HAC/1028/2026: from 6 October 2027 if your volume of operations exceeded 8 million euros the previous year, from 6 October 2028 for everyone else.
Does it apply to you?
What Verifactu means for a foreign company
The obligation follows the invoice, not the passport. If the invoice is legally Spanish, the software behind it has to be compliant, even if your company is headquartered in Berlin, London or New York.
Spanish subsidiary (SL / SA)
A locally incorporated entity is a corporate-tax payer, in scope from 1 January 2027, same as any Spanish company.
Permanent establishment / branch
A non-resident with a permanent establishment in Spain that issues Spanish invoices is explicitly named in the rules, from 1 July 2027.
Selling into Spain, no local entity
If you have no Spanish establishment and issue invoices under your own country's rules, Verifactu may not apply, but this is exactly the grey area worth a 30-minute check.
The common trap: assuming your global ERP or your payment provider "handles Spain". Unless that software is adapted to Verifactu and configured for your Spanish entity, the invoices it produces will not comply, and the 50,000 € exposure is on you, not the vendor.
How we help
Three starting points, one call in English
We specialise in Holded (native Verifactu support and an AEAT Social Collaborator), but we are not locked to it. We meet your stack where it is.
01
Already on Holded
We audit your current configuration (invoice series, integrations, historical data), find the gaps, set VeriFactu or No-VeriFactu mode correctly and document it for your accountant.
02
Migrating from a foreign ERP or spreadsheets
A structured move to Verifactu-ready software for your Spanish-scope invoicing, with a parallel period, history preserved and a compliant flow from the first invoice, while your global ERP stays your source of truth.
03
You issue invoices from your own platform
If your SaaS, marketplace or custom store emits the invoices itself, that system is your billing system: SHA-256 signing, hash chaining and direct submission to the AEAT. We build it to RD 1007/2023 + Order HAC/1177/2024.
FAQ
Verifactu questions foreign companies ask us
Does Verifactu apply to my foreign company if we invoice in Spain?
If your entity issues invoices under Spanish tax rules, yes. Verifactu applies to corporate-tax payers (Spanish subsidiaries, SL/SA companies) from 1 January 2027, and to individuals under IRPF, non-residents with a permanent establishment in Spain, and income-attribution entities from 1 July 2027. The trigger is issuing a Spanish invoice, not where your headquarters sits, so a foreign group with a Spanish branch or a permanent establishment is squarely in scope.
We invoice everything from our home-country ERP. Is that a problem?
It can be. If the invoices are legally Spanish invoices (issued by your Spanish entity or permanent establishment), the software that produces them has to meet Verifactu's technical requirements: a chained SHA-256 hash, a compliant QR code, and either real-time reporting to the AEAT or complete tamper-proof retention. A foreign ERP that was never adapted for Spain usually cannot do this out of the box. The clean route is to issue the Spanish-scope invoices from software adapted to Verifactu (such as Holded) while your global ERP stays your system of record.
Is there a list of certified or approved software?
No. The AEAT does not certify, validate or approve billing software and publishes no official list. From the deadline, any billing system you use must meet the technical spec of Royal Decree 1007/2023 and Order HAC/1177/2024 (a SHA-256 fingerprint chained to the previous record, a Verifactu QR code, and one of the two operating modes), and the producer vouches for that with a signed statement of compliance (declaración responsable, article 13 of RD 1007/2023). Ask your vendor for it. Handwritten invoices fall outside Verifactu. According to the AEAT, a spreadsheet or word processor used only to type, print and store invoices is not a billing system; if it also processes that data to produce tax ledgers or accounts (with macros, for example), it is. The prudent route is adapted software or the AEAT's free invoicing app.
VeriFactu vs No-VeriFactu mode: which should we pick?
VeriFactu mode sends each invoice record to the AEAT in real time and, in exchange, reduces your retention obligations. No-VeriFactu mode keeps everything locally with full tamper-proof retention and complete technical responsibility for traceability. For most foreign companies without a strong connectivity or data-residency constraint, VeriFactu mode is the simpler, lower-risk choice.
What about invoices generated automatically from Stripe, Shopify or our marketplace?
This is where foreign companies get caught. A poorly wired integration can emit invoices that break the Verifactu chain: missing mandatory fields, no hash chaining, wrong series. An automatically generated invoice has to be exactly as compliant as one typed by hand. We audit every inbound flow (payment gateway, e-commerce, marketplace) and make sure the invoices they create are conformant.
What is the penalty for non-compliance?
Up to 50,000 € per financial year for using billing software that does not meet the technical requirements (article 201 bis of the General Tax Law). The fine is tied to the system, not to each invoice.
Has Verifactu been postponed again?
On 5 October 2026 the Spanish Ministry of Finance announced it will delay Verifactu to October 2028 for companies and the self-employed, to align it with mandatory B2B e-invoicing. Until that change is published in the BOE (the official gazette), the legal dates remain 1 January 2027 for corporate-tax payers and 1 July 2027 for everyone else. B2B e-invoicing is a separate obligation (Royal Decree 238/2026): from 6 October 2027 for businesses whose volume of operations exceeded 8 million euros in the previous year, and from 6 October 2028 for the rest.
Does it apply in the Basque Country or Navarre?
No. Businesses taxed by the Basque provincial tax authorities (TicketBAI, Batuz in Bizkaia) or by Navarre have their own regimes and are outside Verifactu.
Do we have to re-issue our historical invoices?
No. There is no retroactive Verifactu. The obligation only applies to invoices issued on or after the effective date for your category (1 January 2027 for companies, 1 July 2027 for the rest). Older invoices are kept under the previous rules; you do not re-chain, re-sign or rewrite them.
How fast can you get us compliant?
Fixed price after a short diagnosis, not by the hour. Auditing and configuring an existing Holded setup is typically a week; a structured migration from another system runs two to four weeks depending on volume and integrations. Every case starts with a free 30-minute call in English where you leave with a written fixed proposal.
Not sure whether Verifactu applies to your company?
30 minutes in English and you leave with a clear answer: whether you are in scope, what is missing, and what it costs to be compliant before 2027. No strings attached.