Sanctions for Not Complying with Verifactu in 2026: Amounts and Deadlines

# Sanctions for Not Complying with Verifactu in 2026: Amounts and Deadlines

The sanctions for not complying with Verifactu in 2026 are a reality that every self-employed individual and SME must know before Hacienda initiates the first sanctioning procedures. The Verifactu system — mandatory for taxpayers using invoicing software — requires that each issued invoice be registered with a verifiable code by the AEAT. Non-compliance may result in fines of up to 50,000 euros per fiscal year, as established in Law 11/2021 on measures to prevent tax fraud (BOE number 164, of July 10, 2021) and its subsequent regulatory development.

If you have not yet adapted your invoicing software or are unsure if you are obligated, this article explains the specific infringements typified by the regulation, the exact amounts you risk, and the deadlines you have to get up to date.

What is Verifactu and Why It Affects Self-Employed in 2026

Verifactu is the invoicing registration system developed by the Regulation approved by Royal Decree 1007/2023 (BOE number 270, of November 13, 2023). Its objective is to ensure that the invoicing software used by companies and self-employed individuals generates immutable records, with a QR code and a chained hash that allows the AEAT to verify the integrity of each invoice.

The self-employed individuals in direct estimation (normal or simplified) who issue invoices with software are obligated to use a program that complies with the technical specifications of Verifactu. Those who tax in modules (objective estimation) and do not use invoicing software are excluded from the scope of application, although they must review their specific situation.

The obligation timeline, according to the regulation in force in 2026, establishes:

• Large companies and tax groups: obligation from July 1, 2025.
• Rest of taxpayers (self-employed and SMEs): obligation from January 1, 2026 (consult the updated conditions at agenciatributaria.gob.es, since the AEAT may publish extensions or technical clarifications).

If your software is not adapted as of today — June 14, 2026 — you are already in a sanctionable situation.

Verifactu Sanction Regime: What Infringements Does the Regulation Typify

The Law 11/2021 introduced in the General Tax Law (LGT) Article 201 bis, which specifically typifies infringements related to invoicing systems. This is the legal framework that supports the sanctions for not complying with Verifactu in 2026.

The infringements are classified into three categories:

1. Use of software that does not meet technical requirements

Using, commercializing, or having installed a invoicing program that:

• Allows maintaining separate accounting records (double accounting).
• Allows not registering, altering, or destroying issued invoices.
• Does not generate the invoicing records required by Verifactu.
• Lacks the certification or responsible declaration from the manufacturer.

Sanction: fixed fine of 50,000 euros per fiscal year in which the non-compliant software was used (Article 201 bis LGT, as per the current wording in 2026).

2. Production of non-homologated software

Manufacturers or distributors of invoicing software who commercialize programs without meeting technical requirements also commit a serious infringement, with sanctions that may reach up to 150,000 euros per fiscal year in which the product was commercialized.

3. Formal infringements in invoice registration

In addition to the specific sanctions under Article 201 bis, the AEAT may apply the general tax infringement regime of the LGT (Articles 198 and following) for formal infringements in the keeping of records, with fines ranging from 150 to 6,000 euros depending on the severity and recurrence.

Specific Sanction Amounts for Verifactu in 2026

To help you assess the real risk, here is a structured summary of the sanction amounts:

Important: the 50,000 euro sanction is applied per fiscal year, not per invoice. This means that a self-employed individual who operated the entire 2026 year with non-compliant software could face a single sanction of 50,000 euros, regardless of the number of invoices issued. However, if the non-compliance extends to 2027, the sanction may be repeated.

Practical Example 1: Self-employed with outdated software

María is a graphic designer self-employed in direct estimation. She issues about 80 invoices per year with an invoicing program that her supplier has not updated to comply with Verifactu. If the AEAT detects the non-compliance during an inspection or through data cross-checking, María could receive a sanction proposal of 50,000 euros corresponding to the 2026 fiscal year, regardless of her annual income of 35,000 euros.

This example illustrates why the risk is disproportionate for many self-employed individuals: the sanction may exceed their annual income significantly.

Practical Example 2: Self-employed who detects the problem and adapts

Carlos is a plumber self-employed who continued using an outdated software in January 2026. In March 2026, he contacts his supplier, updates the program to a certified Verifactu version, and regularizes his situation. If the AEAT initiates actions, the fact of voluntarily correcting the non-compliance before any formal request may be considered an aggravating factor, although it does not automatically eliminate the responsibility for the period January-March. The LGT provides reductions of up to 40% in the sanction if paid voluntarily without appeal (Article 188 LGT).

How Hacienda Knows if Your Software Does Not Comply with Verifactu

The AEAT has several mechanisms to detect non-compliance:

• Voluntary submission of records: in the Verifactu mode, the software can automatically send invoicing records to the AEAT in real time. If no records are received from an obligated taxpayer, it is a warning signal.
• Inspections and verifications: during an inspection visit, agents may request access to the invoicing software and verify if it meets the technical requirements.
• Cross-checking with third parties: the AEAT cross-checks data from Model 347 (transactions with third parties) with IVA records. Significant discrepancies may trigger actions.
• Denunciations by competitors or customers: the regulation allows third parties to report possible non-compliance to the AEAT.

Verifactu Sanctions and Their Relationship with Other Tax Obligations of the Self-Employed

Non-compliance with Verifactu is not an isolated infringement. It may have cascading effects on other obligations:

• IVA: if the invoices do not meet formal requirements, the AEAT may question the deductible IVA from your clients, which may generate commercial conflicts.
• IRPF: expenses and income registered with non-compliant software may be subject to regularization in the income tax return.
• Books of records: incorrect keeping of the books of issued and received invoices may generate additional sanctions for formal non-compliance (Article 198 LGT).

Therefore, adapting the invoicing software is not just to avoid a fine: it is to protect the coherence of your entire fiscal accounting.

Key Deadlines and What to Do Now

If your software is not adapted as of June 14, 2026, these are the recommended steps:

1. Verify with your software provider if the version you use already complies with Verifactu. Request written confirmation and keep the manufacturer's responsible declaration.
2. Update or change your software as soon as possible. There are solutions available on the market — including some free for self-employed with low invoicing — that already meet the technical requirements.
3. Review invoices issued in 2026: if you have issued invoices with non-compliant software, consult a tax advisor to determine if any voluntary regularization is possible.
4. Check the AEAT's electronic office (agenciatributaria.gob.es) to verify if new instructions, extensions, or technical clarifications about Verifactu in 2026 have been published.
5. Keep all documentation: certificates from the provider, software update invoices, and any communication with the AEAT.

If you have doubts about your specific situation, use our fiscal risk calculator for self-employed to estimate the potential impact of a non-compliance in your case.

Reduction of Sanctions: When and How to Apply It

The General Tax Law provides reductions in tax sanctions under certain circumstances:

• 30% reduction if the taxpayer does not appeal the sanction and pays it within the voluntary period (Article 188.1.b LGT).
• Additional 40% reduction if the taxpayer also pays in the voluntary period without deferral (Article 188.3 LGT).
• Reduction for compliance: if the taxpayer accepts the sanction calculation, an additional 30% reduction may apply.

In practice, a 50,000 euro sanction could be reduced to approximately 21,000 euros if the self-employed accepts the calculation and pays within the voluntary period without appealing. Nevertheless, it is still a very high amount for most self-employed individuals, reinforcing the importance of preventive adaptation.

Sources and Reference Legislation

• Law 11/2021, of July 9, on measures to prevent and combat tax fraud (BOE number 164, of July 10, 2021). Introduces Article 201 bis in the General Tax Law.
• Royal Decree 1007/2023, of December 5, approving the Regulation that establishes the requirements that information systems and electronic programs must adopt to support invoicing processes (BOE number 270, of November 13, 2023).
• Law 58/2003, of December 17, General Tax Law (LGT), Articles 188, 198, and 201 bis.
• AEAT — Information on Verifactu and invoicing systems: agenciatributaria.gob.es
• Order HAC/1177/2023 and subsequent technical developments published by the AEAT on Verifactu specifications.