VeriFactu for freelancers: what it is, when it takes effect, and how to prepare before July 2027

If you're a freelancer (autónomo) or run a small business in Spain, chances are you've heard the word VeriFactu at some point in the past year and thought two things: "this sounds like a hassle" and "I'll deal with it when the time comes." Let's take both off your plate.

VeriFactu is the Spanish tax agency's (AEAT) technical answer to a very specific problem: ensuring no invoicing software allows the alteration or concealment of invoices already issued. It stems from Royal Decree 1007/2023 of 5 December, which develops article 29.2.j of the General Tax Law and establishes the requirements any invoicing program must meet.

The three things VeriFactu forces your software to do

The Regulation doesn't change what YOU have to do. It changes what your software has to guarantee. Specifically, three things:

1. SHA-256 hash chain: each issued invoice is chained by a cryptographic fingerprint (hash) to the previous one. If anyone tries to modify an old invoice, the chain breaks and the tampering leaves evidence.
2. QR verification code: each invoice PDF must carry a QR with the fields set by Order HAC/1177/2024 — issuer NIF, invoice number and series, date, and total amount. Any recipient can scan it and check the invoice was declared.
3. Immutable invoicing registry: the software must keep an append-only registry (no deletions) of all operations and, optionally, submit them to the AEAT in real time.

The dates: who must comply and from when

The Regulation applies in two waves, depending on the taxpayer's fiscal regime:

• 1 January 2027 — Corporate Income Tax (IS) taxpayers: limited companies (SL), public limited companies (SA), and other legal persons.
• 1 July 2027 — everyone else: freelancers (autónomos on IRPF), community property (comunidades de bienes), landlords, and generally any natural person or entity without legal personality issuing invoices for their economic activity.

Both dates are set by the Regulation itself after the extensions approved during 2024 and 2025. Nobody is exempt for invoicing infrequently. If you issue a single invoice per year, your software must comply with VeriFactu from your applicable date.

"What if I keep using Word or Excel?"

After July 2027 you can't. Word and Excel do not meet the requirements the Regulation imposes on an invoicing information system (SIF): no chain, no QR, no immutable registry. Nor does a manually crafted PDF template. After your date, holding or using one of those "programs" to issue invoices is the infringement under article 201 bis LGT. (Fully handwritten paper invoices sit outside the Regulation's scope — but essentially nobody invoices that way anymore.)

The penalties (and why they change your maths)

The sanctions regime lives in the new article 201 bis of the General Tax Law. Two distinct offences, each with its own fine:

• Producing or marketing software that does not comply with VeriFactu: fine of €150,000 per fiscal year and program type. This falls on whoever builds or sells the software.
• Holding or using non-compliant software: fixed fine of €50,000 per fiscal year. This falls directly on the taxpayer who uses it.

These are not symbolic sanctions. They are the numbers driving software companies and taxpayers to certify their systems ahead of the deadline.

How to prepare before your date

If you're a freelancer, you have until July 2027. That sounds far away, but system migrations are painful and much easier when there's no pressure. A simple plan:

1. Now — before year-end: list every tool you currently use to issue invoices. Word, Excel, hand-made PDFs, an old POS, a template from your accountant… everything.
2. Q1 2027: choose a program with explicit "VeriFactu compliance" or "VeriFactu mode". Modernness alone isn't enough: ask them for the declaración responsable required under article 13 of RD 1007/2023.
3. Q2 2027: migrate your history. A serious program imports your past invoices from a ZIP and classifies them without you having to type anything.
4. 1 July 2027: issue your first VeriFactu invoice with SHA-256 chain and QR. Done.

What if I'm coming from another program?

Switching invoicing software has a bad reputation, but VeriFactu is not a reason to delay it — quite the opposite: it forces you to make the change with time to spare. A serious program imports your history in a single step — Billy does it from a ZIP of your old PDFs; the AI reads them, classifies them as issued or received, and brings your books up to date without any typing.

Executive summary

• VeriFactu is mandatory for freelancers from 1 July 2027.
• Your software must do three things: SHA-256 chain, QR and append-only registry.
• Non-compliance fines range from €50,000 to €150,000 per fiscal year.
• Preparing the migration a year in advance is far cheaper than doing it in June.