As of 1 January 2026, In Spain, the invoicing system will undergo an unprecedented transformation. With the entry into force of the Regulation on Computerised Invoicing Systems (ICS) approved by the Royal Decree 1007/2023 and the deployment of the system VeriFactu, In the next few months, millions of self-employed people and businesses will have to adapt the way they issue their invoices.
The measure aims to strengthen fiscal control and eradicate the use of “dual-use” software, which can hide income from the tax authorities.
This transition poses a very concrete question for professionals and small businesses: Will it be possible to continue invoicing with Excel or Word after 2026? The answer, according to the Directorate-General for Taxation (binding consultation V2653-24), it is neither an outright “yes” nor an outright “no”, but rather a depends on use to be made of these tools.
If they are used in a purely manual way, such as simple word processing or spreadsheets without automation, their use remains valid. However, any function involving automated data processing, storage or generation will need to comply with the technical requirements of VeriFactu.
The change goes beyond a legal obligation. It represents the definitive step towards full digitisation of invoicing in Spain, in a context where the B2B e-invoice will also become mandatory in the coming years. Therefore, rather than an imposition, the new regulation is seen as an opportunity to modernise processes, reduce errors and gain traceability.
Regulatory framework: Anti-Fraud Law and the VeriFactu system
The new regulatory framework for invoicing in Spain is based on two legal pillars: the Law 11/2021 on Measures to Prevent and Combat Tax Fraud -known as Anti-Fraud Law- and its development through the Royal Decree 1007/2023, which approves the Regulation on Computerised Invoicing Systems (ICS).
Both rules are born with a clear objective: ensuring the integrity, traceability and inviolability of billing records. In practical terms, this means that every invoice must be recorded in a system that prevents subsequent alterations, deletions or manipulations. The message from the Treasury is unambiguous: digital accounting must be transparent, verifiable and end-to-end traceable.
1. VeriFactu: the backbone of the new system
The VeriFactu System is the tool that materialises this control. It is a technical standard that invoicing programmes -both public and private- must comply with in order to be considered legal. Its main requirements include the following:
- Structured billing register: each invoice shall generate an XML file in a predefined format.
- Hash string: each record will include the fingerprint of the previous one, creating an unalterable sequence.
- Event registration: any relevant action (creation, cancellation, closure of the programme) shall be noted.
- QR code required: will allow immediate verification of the authenticity of the invoice.
- Inalterability and preservation: the data must be kept intact for a minimum period of 4 to 6 years.
In essence, VeriFactu turns every invoice into a traceable tax document, digitally sealed, and prevents any further manipulation.
2. Timetable for implementation
The roll-out of the system will be gradual:
- From 1 January 2026: compulsory for all companies and companies subject to the Corporate income tax.
- From 1 July 2026: compulsory for self-employed and economically active individuals.
These dates mark a before and after: from then on, any software that generates invoices must comply with the VeriFactu specifications or it will no longer be valid for tax purposes.
Penalties and consequences
Non-compliance with the regulation is not minor. Penalties can reach up to 50,000 per tax year, especially in cases of use of software that allows sales to be concealed or records to be altered. Beyond the fine, the reputational risk and possible loss of confidence of customers or suppliers can have an even greater economic impact.
Is it possible to continue invoicing with Excel or Word after 2026?
The most widespread doubt among the self-employed and small businesses is straightforward: Will the possibility of issuing invoices with Excel or Word disappear?
The official response, according to the binding consultation V2653-24 of the Directorate-General for Taxation (published on 27 December 2024), is that they may continue to be used, but only under very specific conditions. The key is how they are used these tools.
1. Permitted uses: manual invoicing without automation
Excel or Word will remain valid if they are used as a purely drafting or typing tool, without any automation or data processing. This includes the following cases:
- They are used as a “digital typewriter”, to enter the data and generate an invoice individually.
- They are not used macros, automatic formulas or templates with calculations.
- No generation of structured records and automatic billing lists.
- Invoices are not kept in searchable or sortable databases or systems.
- They are not produced automatically VAT, IRPF books or tax forms.
In this context, Excel or Word are not considered to be a Computerised Invoicing System (CIS). and therefore, are not subject to VeriFactu's requirements..
This option is especially practical for professionals who issue few invoices per year, as consultants, therapists or freelancers in activities with low turnover.
2. Not permitted uses: automation or structured management
On the other hand, when Excel or Word are used as a management tool -and not just deeds - are automatically considered to be a SIF, This means that all technical requirements of VeriFactu must be fulfilled. This happens in the following cases:
- They generate automatic series of invoices or linked numbers.
- They are used smart macros or templates that calculate totals or VAT.
- The following are created automatic listings or reports for fiscal or accounting control.
- Invoices are stored in structured folders or databases.
- Files are linked to accounting, CRM or ERP software.
In these situations, Excel or Word are no longer simple office tools, but become a automated billing system, which requires its certification under the VeriFactu standard.
3. Practical implications
In practice, this divides users into two groups:
- Self-employed with low turnover, The new users, who will still be able to use Excel or Word manually, albeit with limitations.
- Medium to high volume companies and freelancers, for whom automation is already an essential part of the process, and who will have to migrate to certified software by 2026.
The threshold is not set by the size of the enterprise, but by the level of automation. In other words: if your Excel “thinks for you”, the tax authorities consider it an invoicing system, and therefore it must comply with VeriFactu.
VeriFactu technical requirements and their practical implications
The system VeriFactu is not an invoicing programme in itself, but a set of technical specifications that all invoicing software must comply with in order to be considered valid before the Tax Agency. Its aim is to ensure that each invoice is unique, traceable and unalterable, eliminating any possibility of further manipulation.
1. Key technical elements of the VeriFactu standard
The Regulation on Computerised Invoicing Systems (ICS) details the minimum requirements for VeriFactu-compatible software:
- Structured registration in XML format:
Each invoice must generate an XML file with standardised fields (identification of the issuer and receiver, amounts, taxes, dates, etc.). This standardised format facilitates automatic reading by the tax authorities and avoids interpretation errors. - Hash string:
Each record includes the fingerprint (hash) of the previous one, which creates a unbroken chain of invoices. If an invoice is deleted or modified, the sequence is broken, leaving an immediate trace of manipulation. - Event registration:
The system must record all significant actions: invoice creation, modifications, programme closures or cancellations. These logs ensure full traceability of the process. - Verifiable QR code:
Each invoice must include a QR code that allows any third party to verify its authenticity directly at the AEAT's electronic headquarters. - Inalterability and preservation:
Invoices cannot be modified after they have been issued. The software must allow exporting and retaining records for at least 4 to 6 years, in accordance with current tax legislation. - Manufacturer's declaration of responsibility:
Developers must submit a declaration to the AEAT certifying that their software meets all the technical and security requirements of the regulation.
2. What it means for businesses and the self-employed
Adopting VeriFactu software is not just a technical issue: it involves a profound operational change in the way they work.
- Accounting, invoicing and ERP systems should be integrated to generate compatible structured records.
- Tax departments should familiarise themselves with XML export and hash control.
- Internal audits and accounting firms should update their procedures to review traceability and storage.
In short, VeriFactu raises transparency to a structural level. Each invoice will be a verifiable link in a chain that the tax authorities will be able to check without relying on manual declarations or accounting books drawn up after the fact.
Penalties and liabilities
The non-compliance of the requirements may result in penalties of up to 50,000 per tax year, especially if the use of “dual-use” software or unregistered invoices is detected.
In addition, software manufacturers are also liable to the administration if they do not comply with certification standards, which introduces an additional layer of control and trust in the market.
Alternatives available: free AEAT application and approved private solutions.
With the implementation of VeriFactu just around the corner, both the Tax Agency (AEAT) and the private sector have prepared different options for the self-employed and businesses to comply with the new regulation. The choice of the most appropriate system will depend on the Turnover, the degree of automation and the technological capacity of each business.
1. The free AEAT application
In October 2025, the Inland Revenue launched its free billing application adapted to VeriFactu, available from the AEAT Electronic Headquarters. This is an official tool that allows you to generate invoices in compliance with the regulations, with the advantage of being completely free of charge and without the need for complex installation.
Main features
- It allows you to issue electronic invoices one by one using a web form.
- Each invoice is automatically sent to the AEAT servers, guaranteeing its traceability.
- Complies with all technical requirements of the VeriFactu standard (XML log, hash chain, QR, etc.).
- It is designed to freelancers and small businesses with a reduced number of monthly invoices.
Limitations
Despite its usefulness, this solution has clear limitations:
- It does not allow automate processes or integrate data with accounting software.
- It does not include functions of stock management, bank reconciliation or financial reporting.
- Not scalable for businesses with high turnover.
- The process remains manual, This may be inefficient in the medium term.
In short, the AEAT's free application is a basic compliance solution, The new solution is ideal for professionals with low turnover or businesses looking to adapt on a temporary basis while they value a more robust private solution.
2. Approved private software: the professional alternative
Companies with a larger volume of operations or that already rely on integrated accounting systems will need to go one step further: adopting an integrated accounting system. approved private software under the VeriFactu standard.
Key benefits
- Full automation of the invoicing process.
- Integration with accounting, treasury and commercial management modules.
- Automatic generation of tax books, reports and tax forms.
- Guaranteed compliance with the technical requirements of the regulation.
- Increased operational efficiency and reduced human error.
Certification and requirements
To be recognised as compatible with VeriFactu, the software must:
- Incorporate all the mechanisms of inalterability, traceability and structured registration required by the AEAT.
- Generate XML files according to the official format.
- Maintain records for the legal retention period.
- Include a manufacturer's declaration of responsibility, which ensures its technical adequacy.
The main platforms in the market - such as Holded, Quipu, Billin, Alegra or Cegid - are already working on certified versions, and many of them are offering specific plans for the self-employed with reduced tariffs or cloud versions.
3. Strategic choice: short term vs. long term
The decision between using the free application or private software will depend on the horizon of the business:
- If the volume of invoices is very low and management remains manual, the AEAT tool will be sufficient.
- If the business seeks to grow or automate processes, If you have a VeriFactu software, you should invest in an approved VeriFactu software from now on.
In the medium term, digitisation will not be an option but a necessity. necessary condition to maintain competitiveness and avoid sanctions.
VeriFactu Exceptions and Exclusions
Although the new invoicing rules will be mandatory for most companies and self-employed people, the Regulation on Computerised Invoicing Systems (ICS) establishes a series of exceptional cases that are exempted from the obligation to adopt VeriFactu. These exceptions meet criteria of proportionality and consistency with other existing tax regimes.
1. Companies covered by the Immediate Supply of Information (SII)
The entities included in the IBS -usually large companies and groups that submit VAT in real time- are already integrated into a system for automatically sending invoicing records to the tax office.
Therefore, do not have to duplicate the obligation through VeriFactu, as its level of fiscal control is equivalent or superior.
2. TicketBAI users in the Basque Country
Companies and self-employed persons operating in the territories of the Basque Country (Álava, Bizkaia and Gipuzkoa) under the system TicketBAI are also exempted from applying VeriFactu, This is an equivalent control model, developed by the Basque tax authorities and fully validated by the AEAT.
In these cases, TicketBAI and VeriFactu are mutually recognised systems.
3. Self-employed under the module regime (objective estimation)
Taxpayers who are covered by the module regime that are not obliged to issue invoices are also excluded from VeriFactu. If, for operational or commercial reasons, they issue an invoice, they may continue to do so. in manual format or with non-automated programmes, provided that a structured billing system is not used.
4. VAT exempt activities
Certain VAT-exempt professional or business activities - such as specific educational or healthcare services - are not obliged to comply with VeriFactu, unless they voluntarily adopt an e-invoicing system.
5. Manual invoicing only
Companies or self-employed persons issuing paper invoices or by purely manual means (chequebooks, forms or even typewriters) are not subject to VeriFactu, since do not use a computerised invoicing system.
However, if at some point they digitise the process or start keeping electronic records, they will have to comply with the requirements of the regulation.
6. Subjects not obliged to invoice under the Invoicing Regulation
Some taxpayers, by the nature of their operations, have no legal obligation to issue an invoice. In these cases, the standard does not require them to adopt VeriFactu or electronic invoicing, although they may do so voluntarily if they wish to improve traceability or facilitate tax management.
Differences between VeriFactu and B2B e-invoicing
One of the most common doubts among entrepreneurs and the self-employed is whether they should VeriFactu and B2B e-invoicing are one and the same. The answer is clear: are not, The two are part of the same tax digitisation process that will be consolidated between 2026 and 2027.
The two regulations complement each other, but they regulate different aspects of the invoicing cycle.
1. What regulates VeriFactu
VeriFactu is focused on the invoicing software and its relationship with the Tax Agency.
Its purpose is to ensure that every invoice issued by means of a computerised system is complete, verifiable and unalterable. It does not regulate the format of invoices or how they are sent to customers, but rather how they are generated and recorded internally.
Key points of VeriFactu:
- Derived from the Law 11/2021 and of the Royal Decree 1007/2023.
- Controls the process of issuing and registration of invoices, not their exchange.
- Applies to all operationsB2B, B2C and B2G (between companies, with individuals or with administrations).
- Forces IT systems to generate structured XML records and to include hash, QR and full traceability.
- It enters into force on 1 January 2026 for companies and the 1 July 2026 for the self-employed.
2. What regulates B2B e-invoicing
The B2B e-invoice, The Law 18/2022, known as the “Create and Grow” Law.”, and regulates the format and the exchange process of business-to-business and business-to-professional invoices.
Its aim is to ensure that all business-to-business relations are managed digitally and in a structured electronic format.
Main features:
- Affects only operations business-to-business (B2B).
- Obliges the issuing and receiving of invoices in the format structured electronic (XML, UBL, Facturae, etc.).
- It seeks to improve commercial traceability and reduce late payments.
- Pending final regulatory development (second public consultation closed in April 2025).
- Its entry into force will be staggered:
- Companies with a turnover of more than 8 million euros: one year after the publication of the final ministerial order.
- Other companies and the self-employed: two years later.
In this case, it is not the broadcasting software that is regulated, but rather the way in which companies exchange their electronic invoices.
3. How they really differ
| Aspect | VeriFactu | B2B e-invoice |
|---|---|---|
| Legal basis | Law 11/2021 and RD 1007/2023 | Law 18/2022 “Create and Grow”.” |
| Approach | Fiscal control of issuance and registration | Digitalisation of business-to-business exchange |
| Scope | All operations (B2B, B2C, B2G) | Only transactions between professionals or companies |
| Required format | Internal XML with hash, QR and traceability | XML, UBL or Facturae as interchange format |
| Target | Preventing fraud and ensuring integrity | Promoting digitisation and reducing late payments |
| Deadlines | 2026 (January and July) | 2026-2027 (depending on company size) |
4. An inevitable transition
VeriFactu and B2B e-invoicing are two sides of the same coinone oriented towards fiscal control, and the other to the business efficiency.
While VeriFactu ensures that every invoice is reliable at source, B2B e-invoicing will ensure that business-to-business transmission is also reliable, creating a tax ecosystem. 100 % digital and verifiable.
Practical recommendations for the self-employed and SMEs
The entry into force of VeriFactu and the imminent obligation of B2B e-invoicing mark the beginning of the end of traditional invoicing. Although the change may seem complex, with the right planning it becomes an opportunity for modernising processes, reducing errors and gaining fiscal efficiency.
These are the main recommendations according to the type of business and level of digitisation.
1. If you issue few invoices per year
If you only generate a few monthly or quarterly invoices, you can continue to use Excel or Word manually, provided that:
- Do not use formulas, macros or automations.
- Enter the data one by one and generate each invoice separately.
- Do not store or classify invoices electronically in a database.
Even so, it is advisable to start to familiarise yourself with the free AEAT application. Using it now will allow you to adapt without stress when the obligation becomes general. In addition, you can ensure that your invoices already comply with the structure required by the tax authorities.
2. If you issue invoices on a frequent basis or you manage several customers
For businesses with regular activity, manual invoicing will soon no longer be viable. In this case, the best strategy is gradually migrate to VeriFactu certified software.
When choosing it, check that:
- The programme is officially approved by the AEAT.
- Enable XML records to be generated and retained in accordance with the regulation.
- Include the manufacturer's declaration of responsibility.
- Provide automatic updates as regulations evolve.
Adopting the software early gives you room to resolve issues, train the team and avoid a last-minute meltdown in 2026.
3. Don't wait for the deadline
Both companies (January 2026) and the self-employed (July 2026) will have to comply with VeriFactu.
Leaving adaptation to the last minute can be a challenge:
- Interruptions in the issuing of invoices.
- Delays in collections or incidents with customers.
- Risk of sanctions of up to 50,000 per financial year.
Planning the transition months in advance reduces costs and stress. Early adapters will also gain a competitive advantage: more streamlined, audited and reliable invoicing.
4. Consult your tax advisor
Every business has nuances. What applies to a self-employed person in modules is not the same as for a trading company with several employees. Therefore, before making any decisions:
- Consult your specific case with a tax advisor or accountant.
- Define whether you are within any exclusion or special regime.
- Evaluate which software is best suited to your operation.
An up-to-date VeriFactu advisor can help you avoid formal errors which, however small they may seem, can lead to significant penalties.
5. Prepare also for the transition to B2B e-invoicing
While VeriFactu will be the first step, the B2B e-invoice will arrive shortly thereafter, probably between 2026 y 2027.
It is therefore advisable to opt from now on for solutions that:
- Allow issue and receive structured electronic invoices (XML, Facturae, UBL).
- Facilitate the integration with other systems (ERP, CRM, banks).
- Meet the standards of safety and traceability required by future legislation.
In conclusion, our recommendation is to take advantage of the verifactu system and use either the free invoicing application of the tax authorities or a private software.
