Verifactu 2026: What is it and when is it mandatory for self-employed individuals

# Verifactu 2026: What is it and when is it mandatory for self-employed individuals

Verifactu is the system for registering and transmitting invoices to the Tax Agency (AEAT) that requires invoicing software to generate a verifiable code in real time for the Tax Agency. For self-employed individuals in direct estimation, the obligation to use homologated software with Verifactu comes into effect on July 1, 2026, according to Royal Decree 1007/2023 and Order HAC/1177/2023 (BOE). If you already have an invoicing program, it is most likely that you will need to update it before that date.

What is Verifactu and why does the Tax Agency implement it

Verifactu (abbreviation for Verification of Invoices) is a subsystem within the Regulation of requirements for information systems and electronic programs that support invoicing processes (known as the "VeriFactu Regulation", approved by Royal Decree 1007/2023, BOE nº 234). Its objective is to eliminate the so-called dual-use software or "caja B": programs that allow modifying or deleting issued invoices without leaving a trace.

The mechanism is simple in concept: each invoice you generate with your software must carry a registration of issuance with a hash code linked to the previous invoice, an electronic signature, and, if you opt for the Verifactu mode, automatic transmission to the AEAT servers. The Tax Agency can thus compare in real time whether the invoices declared by a self-employed individual match those they have issued.

There are two modes within the regulation:

• Verifactu proper: the software sends each invoice registration to the AEAT at the time of issuance. The taxpayer does not need to do anything additional; the program manages it.
• Non-Verifactu (with internal registration): the software generates the chain and signature, but does not automatically send the data to the AEAT. The Tax Agency can request them during an inspection.

Most software providers for self-employed individuals are opting for the Verifactu mode (with automatic transmission), because it simplifies compliance and reduces the risk of requirements.

From when is Verifactu mandatory for self-employed individuals

The implementation schedule established in Royal Decree 1007/2023 (BOE) distinguishes between two groups:

This means that, if you are a self-employed individual in direct estimation (normal or simplified) and issue invoices with an information system, from July 1, 2026, that system must be adapted to the VeriFactu Regulation. Using non-homologated software from that date may result in penalties of up to €50,000 per fiscal year (Article 201 bis of the General Tax Law, according to the modification introduced by Law 11/2021).

Important: the obligation falls on the software, not directly on the self-employed individual. However, if you continue using a non-adapted program after July 1, 2026, you are the one who violates the regulation.

Verifactu and electronic invoice: Are they the same?

No, although they are often confused. They are two distinct obligations that coincide in time:

• Electronic invoice (Law Crea y Crece, Law 18/2022): requires issuing invoices in structured format (Facturae or UBL) between businesses and professionals. Its implementation schedule for self-employed individuals with sales under 8 M € is pending definitive regulatory confirmation in 2026 (AEAT).
• Verifactu: requires invoicing software to generate records with chained hash codes and, optionally, transmit them to the AEAT. It affects any self-employed individual using an information system for invoicing, regardless of whether they issue paper or electronic invoices.

In practice, many programs are integrating both functionalities in the same update, so if you update your software for Verifactu, it is likely that you will also be ready for the electronic invoice.

What should a self-employed individual do before July 1, 2026

The adaptation process has three specific steps:

1. Verify if your current software is homologated: consult with your provider if their program already complies with the VeriFactu Regulation. The AEAT does not publish an official list of homologated software, but providers must declare the conformity of their product.
2. Update or change the program: if your provider has not adapted the software, you will need to migrate to one that does. There are free and paid options in the market.
3. Review your internal processes: if you invoice manually (in Word, Excel, or on paper), technically you are not obligated by Verifactu, but you are by other registration obligations. Consult with your tax advisor if your specific situation requires adaptation.

And if I invoice on paper or with Word templates?

The VeriFactu Regulation applies to information systems for invoicing. If you issue invoices exclusively on paper or with tools that are not invoicing programs (such as a word processor without an invoicing module), the obligation does not directly affect you. However, the AEAT recommends migrating to digital systems to facilitate compliance with other obligations (AEAT, electronic headquarters).

Practical example: How Verifactu works in daily life

Imagine you are a self-employed graphic designer and issue 15 invoices a month with an invoicing program adapted to Verifactu:

1. You create the invoice nº 2026/047 for an amount of €1,200 + VAT.
2. Your software automatically generates a registration of issuance that includes: invoice number, date, emitter's VAT number, recipient's VAT number, taxable base, VAT amount, and a hash code calculated from the data of that invoice and the hash of the previous invoice (chaining).
3. If you have opted for the Verifactu mode, the program sends that registration to the AEAT in real time. You receive a QR code that you can include in the invoice for your client to verify its authenticity on the AEAT's electronic headquarters.
4. If the Tax Agency requests your records during an inspection, the system guarantees that you could not have modified or deleted any invoice without leaving a trace.

This process is transparent for the self-employed individual: you do not need to do anything additional beyond using the software correctly.

Example of penalty for non-compliance

Suppose a self-employed individual with an annual turnover of €80,000 continues using an invoicing software not adapted to Verifactu from July 1, 2026. According to Article 201 bis of the General Tax Law (modified by Law 11/2021, BOE):

• The penalty for using information systems that do not meet regulatory requirements can reach up to €50,000 per fiscal year.
• If the software also allowed altering records, the penalty may increase.
• Non-compliance may also lead to a compliance procedure for all unprescribed fiscal years.

In comparison, the cost of updating or changing invoicing software typically ranges between €0 (homologated free options) and €300-600 annually for paid solutions with support. The cost-risk relationship is clear.

Verifactu and the model 303: Does it change anything in the IVA declaration?

Verifactu does not modify the procedure for presenting the model 303 (trimestral self-assessment of IVA) or the model 130 (fractional payment of IRPF). These models continue to be submitted with the same periodicity and deadlines.

What may change is the ability of the Tax Agency to cross-check data: with real-time invoicing records, the AEAT can more easily detect discrepancies between issued invoices and the taxable bases declared in the model 303. This reinforces the importance of maintaining an orderly accounting system and ensuring that declared amounts exactly match invoicing records.

Questions to ask your software provider before July 1, 2026

Before considering your obligation fulfilled, verify these points with your provider:

• Does the program generate the chained records with hash according to the VeriFactu Regulation?
• Does it send the records to the AEAT in real time (Verifactu mode) or store them locally (non-Verifactu mode)?
• Does it include the QR code of verification in the issued invoices?
• Is it prepared for the electronic invoice in Facturae or UBL format?
• What happens with invoices issued before July 1, 2026? (It is not necessary to migrate the historical data, but it is advisable to confirm it.)

If your provider cannot answer these questions clearly, it is a signal that you should look for an alternative before the deadline.

Resources for self-employed individuals: where to get information and what tools to use

The AEAT has published technical documentation on the VeriFactu Regulation on its electronic headquarters (agenciatributaria.gob.es), including technical specifications for developers and an updated section of frequently asked questions. It is the mandatory starting point before making any decision about your software.

If you have doubts about how Verifactu affects your specific situation—especially if you invoice to individuals, use modules, or have IVA-exempt activities—consult a registered tax advisor. The particularities of each regime may involve nuances not covered by general legislation.

You can use our deductible expenses calculator for self-employed individuals to estimate the fiscal impact of the technological adaptation (the cost of the new software may be deductible as an activity expense in the model 130 and in the income tax return).

Sources and reference legislation

• Royal Decree 1007/2023, of December 5, approving the Regulation establishing the requirements that information systems and electronic programs must adopt to support invoicing processes of entrepreneurs and professionals (BOE nº 234, December 6, 2023).
• Order HAC/1177/2023, of November 8, developing the technical specifications of the VeriFactu Regulation (BOE).
• Law 11/2021, of July 9, on measures for prevention and combat of tax fraud, introducing Article 201 bis in the General Tax Law (BOE nº 164).
• Law 18/2022 (Law Crea y Crece), of September 28, on electronic invoices between entrepreneurs (BOE nº 234).
• AEAT — Electronic headquarters: agenciatributaria.gob.es, section VeriFactu and electronic invoice.
• BOE — boe.es.