Verifactu vs Electronic Invoice: Differences and What Applies to You in 2026

# Verifactu vs Electronic Invoice: Differences and What Applies to You in 2026

Verifactu and the electronic invoice are two distinct fiscal obligations that in 2026 cause confusion among self-employed individuals and small businesses. The structured electronic invoice (Law Crea and Crece) affects relationships between companies and self-employed individuals (B2B), while Verifactu is a verification system for billing records that the Tax Agency requires from software programs. Knowing which applies to you—and when—is key to avoiding penalties.

What is Verifactu and How Does It Differ from the Electronic Invoice

Verifactu (short for Verification of Invoices) is a system regulated by the Regulation on the requirements for billing software systems and programs (Royal Decree 1007/2023, BOE of 5 October 2023). Its goal is to ensure that the software you use to issue invoices does not allow altering, deleting, or falsifying records. It is not an invoice format: it is a requirement on the software program you use.

The structured electronic invoice, on the other hand, arises from the Law 18/2022 (Law Crea and Crece) and requires issuing invoices in a digital structured format (such as Facturae or UBL) between entrepreneurs and professionals. Here the focus is on the format of the document you send to your client.

In summary:

• Verifactu: affects billing software. It requires the program to generate immutable records and send them (or allow sending) to the AEAT in real time.
• Electronic invoice (Crea and Crece): affects the format of the document you issue. It requires using machine-readable structured formats in B2B operations.

Both can coincide in your activity, but they are independent regulatory frameworks with distinct calendars and requirements.

How Verifactu Works: What Your Software Must Meet

Royal Decree 1007/2023 (AEAT) establishes that billing software systems must meet a series of technical requirements from 1 July 2025 for companies and from 1 January 2026 for self-employed individuals and other obligated parties (according to the regulation in force in 2026; verify the updated dates on agenciatributaria.gob.es, as they may have been extended).

The main requirements your software must meet under Verifactu are:

1. Immutable record: each invoice generates a record that cannot be modified or deleted without leaving a trace.
2. Linked records: each record is linked to the previous one via a cryptographic hash, preventing retroactive manipulations.
3. Voluntary or mandatory submission to the AEAT: if the software is Verifactu, it automatically sends the records to the Tax Agency. If not, it must still meet the immutability requirements but without automatic submission.
4. QR code on the invoice: invoices issued with Verifactu software must include a QR code allowing the recipient to verify the invoice on the AEAT's electronic headquarters.

What this means for you as a self-employed individual: you don't need to do anything directly with Verifactu except ensuring that the invoicing software you use already complies with the regulation. The technical responsibility falls on the software provider, but the fiscal responsibility of using a certified system is yours.

When is the Electronic Invoice Mandatory for Self-Employed Individuals in 2026

The structured electronic invoice (Law Crea and Crece) has a phased implementation schedule. According to the regulation in force in 2026 and the pending regulatory development awaiting final approval:

• Companies with sales exceeding 8 million euros: obligation is already in effect since 2025.
• Rest of entrepreneurs and self-employed individuals (sales below 8 million euros): the obligation activates when the development regulation comes into force and the established period has elapsed (check the updated status on agenciatributaria.gob.es, as of the date of this article, the final regulation was pending publication in the BOE).

What is clear is that the electronic invoice is only mandatory in B2B operations (between entrepreneurs and professionals). Invoices to end consumers (B2C) are not affected by this obligation.

Important: if you already issue invoices through the public platform FACe or the AEAT's system for operations with the Public Administration, you are already complying with the electronic invoice requirement in that area. This is independent of the B2B obligation under Crea and Crece.

Practical Example 1: Self-Employed Individual with Standard Invoicing Software

Imagine you are a graphic designer self-employed individual, invoice 45,000 € annually, and use a desktop invoicing software you bought three years ago.

Situation regarding Verifactu: your software must have been updated by the provider to comply with Royal Decree 1007/2023. If not, you are using an unapproved system and could face penalties (the Anti-Fraud Law, Law 11/2021, establishes fines of up to 50,000 € for using software that does not meet the requirements). Contact your provider to confirm the approval.

Situation regarding the electronic invoice: if your clients are companies or self-employed individuals (B2B), you will need to issue structured invoices when the Crea and Crece regulation comes into force for your bracket. If your clients are individuals, this obligation does not apply to you.

Immediate action: verify with your software provider whether it already complies with Verifactu and whether it has plans to integrate structured invoice issuance.

Practical Example 2: Self-Employed Individual Using a Spreadsheet or Word

If you issue invoices using Excel, Word, or any tool that is not a specific invoicing software, you must know that these tools cannot meet Verifactu requirements by design: they do not generate chained or immutable records.

This means that, from the date of obligation for self-employed individuals, you will no longer be able to use spreadsheets for invoicing if you are subject to the regulation. You will need to migrate to an approved software.

The AEAT has published information on the requirements that systems must meet on its electronic headquarters (agenciatributaria.gob.es). Some free or low-cost software providers have already adapted their tools.

Estimated cost: approved invoicing software for self-employed individuals ranges from 0 € (free solutions with basic features) to 30-50 €/month for complete solutions with integrated accounting. Some are partially covered by the Digital Kit (according to the beneficiary segment in force in 2026).

What Happens If You Don't Comply: Applicable Penalties

The Law 11/2021 on measures to prevent and combat tax fraud (BOE of 10 July 2021) introduced specific penalties for using software with double use or that does not meet immutability requirements:

• Fine of up to 50,000 € for the production, marketing, or possession of software that allows manipulation of accounting or invoicing records.
• Additional penalties for non-compliance with the obligation to issue structured electronic invoices, whose specific penalty regime will be developed in the Crea and Crece regulation.

The risk is not only financial: using unapproved software may be interpreted by the Tax Agency as an indication of income concealment during an inspection.

Verifactu and VAT: How It Affects Your Declarations

One of the practical effects of Verifactu is that the Tax Agency will have real-time access to the billing records of those using software with automatic submission. This has direct implications for your VAT declarations (Model 303) and IRPF (Model 130 or annual declaration):

• The data of your issued invoices will be available on the AEAT's headquarters, which may facilitate the detection of discrepancies between declared and invoiced amounts.
• If you are already in the SII (Immediate Information Supply), Verifactu does not add new obligations in that regard, as SII already implies the submission of billing records.
• For the rest of self-employed individuals, Verifactu represents greater traceability of their activity before the Tax Agency.

This is not necessarily negative: if you keep your invoicing up to date and declare correctly, the traceability protects you against unfounded claims.

How to Know What Applies to You: Decision Tree

Use this scheme to identify your situation:

Do you use invoicing software?

• Yes → Check with the provider whether the program complies with Royal Decree 1007/2023 (Verifactu).
• No (you use Excel/Word) → You must migrate to an approved software before the obligation date.

Do you invoice other companies or self-employed individuals (B2B)?

• Yes → You will be required to issue structured electronic invoices when the Crea and Crece regulation comes into force for your bracket.
• No (you only invoice individuals) → The obligation to issue B2B electronic invoices does not apply to you, but Verifactu does.

Do you invoice the Public Administration?

• Yes → You already must issue electronic invoices (pre-existing obligation, independent of Crea and Crece).

Specific Steps to Comply in 2026

1. Contact your software provider and request written confirmation that the program complies with Royal Decree 1007/2023.
2. If you don't have software, evaluate approved options. Check if you can access financing through the Digital Kit.
3. Review your clients: identify which are B2B to anticipate the obligation to issue structured electronic invoices.
4. Update your invoice templates to include the QR code if your software already generates it.
5. Check the status of the Crea and Crece regulation on agenciatributaria.gob.es, as deadlines may have changed.

If you have doubts about how it affects your specific situation, you can use the simulation and consultation tools available on the AEAT's electronic headquarters or consult a tax advisor.

Sources and Reference Legislation

• Royal Decree 1007/2023, of 5 October, approving the Regulation establishing the requirements that billing software systems and programs must adopt (BOE number 239, of 6 October 2023).
• Law 18/2022 (Law Crea and Crece), of 28 September, on the creation and growth of companies (BOE number 234, of 29 September 2022).
• Law 11/2021, of 9 July, on measures to prevent and combat tax fraud (BOE number 164, of 10 July 2021).
• AEAT — Electronic Headquarters: agenciatributaria.gob.es (section Verifactu and electronic invoice).
• BOE — boe.es.