New invoicing regulation for freelancers and companies: what changes and when it takes effect
As you may have heard in the media, a new regulation has been approved regarding the obligations of freelancers and companies in relation to the invoices they issue.
In fact, there are two overlapping regulations that may cause some confusion:
The first, commonly known as VERIFACTU, aims to reduce tax fraud and will require freelancers and companies to ensure, among other things, that invoices cannot be modified once issued.
The second, related to electronic invoicing under the “Create and Grow” Law of 2022, seeks to promote digitalisation and eliminate the use of paper in invoicing between businesses (B2B).
This second regulation is still pending approval, so its exact requirements and implementation timeline are not yet defined, although it is expected to take effect around 2027. As more details become available, we will keep you informed of the implications in each case.
What the new VERIFACTU regulation covers
This newsletter focuses on the first regulation, which defines the requirements for Invoicing Software Systems (SIF).
According to this law, all entrepreneurs and professionals must issue and store invoices using software that locks the issued data and guarantees integrity, preservation, and traceability.
The regulation establishes two valid modalities for compliance:
1) VERI*FACTU mode: the software must automatically send a record of each invoice to the Tax Agency immediately after issuance. This prevents later alterations and guarantees preservation. Invoices under this mode include a QR code and can be verified by the recipient through the Tax Agency’s online platform.
2) NON-VERI*FACTU mode: does not require immediate submission to the Tax Agency, although information must be sent if requested. However, it requires additional security measures, such as a digital signature from the issuing system and a log of all system activities. Invoices also include a QR code, but they are not accessible online.
Who is obliged and who is not (official AEAT summary)
a) Obliged (general scope):
Entrepreneurs and professionals (individuals or legal entities) subject to Personal Income Tax (IRPF), Corporate Tax (IS), or Non-Resident Income Tax (IRNR) with a permanent establishment in Spain, domiciled in the common territory (Basque Country and Navarra excluded).
The obligation applies to all invoices, full or simplified, regardless of the recipient.
b) Not obliged (main exclusions):
Taxpayers under the Immediate Supply of Information (SII) system.
Transactions not required to issue an invoice according to the Invoicing Obligations Regulation (ROF) or with specific authorisation not to issue invoices.
Issuing invoices without an SIF: using Word or Excel only to draft, print or store invoices (without processing data for VAT/IRPF or accounting books) is not considered an SIF and therefore not subject to the regulation. However, if the spreadsheet processes data (e.g. through macros generating accounting books), the regulation does apply.
The Spanish Tax Agency (AEAT) has made a free basic application available for small operators who do not need their own SIF (VeriFactu mode), allowing them to issue invoices and generate compliant records.
Implementation timeline
I. Corporate Taxpayers (IS): systems must be adapted before 01/01/2026.
II. Other obliged parties (freelancers): systems must be adapted before 01/07/2026.