Royal Decree 254/2025 deferred the original calendar of RD 1007/2023. The new official entry-into-force dates are 1 January 2027 for entities subject to Spanish corporate income tax and 1 July 2027 for self-employed and the remaining SMEs. This guide breaks down every milestone, the affected taxpayer profiles and the real penalties for non-compliance under Spanish Law 11/2021.
Updated: 14 May 2026 Reviewed by the Dokuflex Tax Compliance Team
General information based on public regulation. For specific cases consult your Spanish tax advisor.
VERI*FACTU is the Spanish certified invoicing computer system regulated by Royal Decree 1007/2023, which forces every invoice issuer to generate a chained invoicing registry per invoice. Each registry includes an SHA-256 cryptographic hash that links to the previous record, a tax QR code printed on the invoice and, in VeriFactu mode, the automatic submission of the registry to the AEAT (the Spanish tax authority) electronic office at the exact moment of issuance.
The legislator's stated goal is to prevent manipulation, concealment or destruction of invoices through dual-use software, a practice that the Spanish Tax Agency has historically fought through Law 11/2021 (the anti-fraud law). VERI*FACTU is the concrete technical implementation of that law in the invoicing layer.
It should not be confused with SII (Immediate Supply of Information): SII reports VAT book records in near-real time and applies only to large companies, VAT groups and entities registered with REDEME. VeriFactu is complementary and covers the rest of the universe of Spanish taxpayers: smaller corporations, SMEs and the self-employed. Companies under SII are exempt from VeriFactu and keep their current SII workflow.
The legal backbone of VERI*FACTU rests on three official pillars worth reading in their original BOE (Spanish Official Gazette) version:
On top of this architecture sits RD 254/2025, which deferred the original dates (which placed the obligation in 2025-2026) until 2027. It is the text that defines the current calendar and the one we detail in the next sections.
Throughout 2024, the technology sector, the associations of tax advisors (AECE, APAFCV) and the employers' confederations (CEOE, ATA) made it clear to the Spanish Ministry of Finance that the original calendar was technically unworkable: many ERPs were not certified, tax-advisor firms had no operational capacity to migrate their clients simultaneously and the AEAT itself needed more time to scale the VeriFactu web-service infrastructure.
RD 254/2025 reflects that demand and defers the calendar. The original dates were 1 July 2025 (corporations) and 1 July 2026 (self-employed and SMEs). The new and current dates are:
Important notice: the deferral does not affect manufacturers' obligations. Since 29 July 2025 they may only sell software compliant with the regulation. It also does not modify either the VeriFactu or the non-VeriFactu mode, which remain valid. If your current software vendor tells you that the obligation hits "in 2026", they are using outdated information that does not reflect RD 254/2025.
The table summarises the mandatory date, recommended mode and specific notes for each Spanish taxpayer profile. The data comes from RD 1007/2023 and its amendment via RD 254/2025.
| Taxpayer profile | Mandatory date | Recommended mode | Notes |
|---|---|---|---|
| Corporations (subject to corporate income tax) | 1 January 2027 | VeriFactu | Mid-to-high invoice volume. Real-time submission lowers the compliance burden during inspections. |
| Self-employed with no employees | 1 July 2027 | VeriFactu | Simple plan. Removing the need for a local XAdES signature simplifies day-to-day operations. |
| SMEs not included in SII | 1 July 2027 | VeriFactu or non-VeriFactu depending on case | If you rely on offline environments or intermittent connectivity (retail, hospitality), evaluate non-VeriFactu. |
| Companies registered with SII | Exempt | Not applicable | They keep SII in near-real time. The AEAT treats both systems as equivalent. |
| Tax advisors and professional firms | 1 July 2027 | VeriFactu (multi-client API) | Recommended adapter with API that centralises all client tax IDs (CIFs) under one console. |
| Non-profits with economic activity | 1 January or 1 July 2027 depending on regime | VeriFactu | Applies if they issue VAT-bearing invoices. Check the specific regime with your advisor. |
Source: RD 1007/2023 (article 4 and first additional provision) as amended by RD 254/2025. General information. For specific cases consult your tax advisor.
Manufacturers and developers of invoicing computer systems follow a different and much stricter calendar. Since 29 July 2025, manufacturers may only sell products compliant with RD 1007/2023 and Order HAC/1177/2024. This date has not been deferred and remains fully in force.
In practice, if your organisation uses an ERP, an invoicing program or a custom application acquired or developed before that date, it is not necessarily certified. The obligation falls on the manufacturer, not on the end user, but the end user is the one who will face penalties for issuing invoices with non-compliant software once their mandatory date arrives (1 Jan 2027 or 1 Jul 2027).
The practical escape route for ERPs that have not certified their software is to integrate a VeriFactu adapter between the ERP and the AEAT. The adapter handles the chained hash, the XAdES signature, the QR code and the submission, without touching the original ERP. To see how an adapter plugs into SAP, Sage, A3, Holded or Dynamics, visit our VeriFactu adapter page.
RD 1007/2023 admits two operational modes. The choice is not trivial: it shapes daily operations, the technical infrastructure and the cost of compliance. Comparative summary:
| Feature | VeriFactu mode | Non-VeriFactu mode |
|---|---|---|
| Real-time submission to AEAT | Yes, record by record | No (local registry; submission only on request) |
| Chained SHA-256 hash | Yes | Yes |
| XAdES electronic signature | Optional (not required) | Mandatory on each record |
| Tax QR on the invoice | Mandatory (with "VERI*FACTU" wording) | Mandatory (without the wording) |
| Recommended for | Most SMEs and self-employed with stable connectivity | Offline environments, very high volumes or sectors with intermittent connectivity |
Switching modes is possible but must be documented. For an expanded analysis by profile, see the comparison on the blog: VeriFactu vs non-VeriFactu: which one suits you in 2027.
The Spanish penalty regime is concentrated in article 201 bis of the General Tax Law, introduced by Law 11/2021. Fines split into two parallel tracks:
Software manufacturer
EUR 1,000 / unit
For each fiscal year in which non-compliant software (under RD 1007/2023) has been marketed or used. The fine applies per unit of product distributed.
Obligated end user
Up to EUR 50,000 / year
Or up to 2% of annual invoiced amount, depending on the scenario. Applies to using computer systems that do not guarantee record integrity and unalterability.
In addition, the AEAT can impose accessory penalties such as publication on the public list of debtors (if the debt remains unpaid), restrictions on deferrals and, in serious cases of wilful manipulation, opening criminal proceedings for tax fraud (article 305 of the Spanish Criminal Code). Technical VeriFactu compliance is therefore a material risk-mitigation measure, not a minor formality. General information. For specific cases consult your Spanish tax advisor.
This action list lets you anticipate compliance without waiting for the last quarter before the mandatory date. We recommend working through these steps during 2026 to arrive in 2027 with a validated rollout.
For many organisations, the most reasonable path is not migrating to a "VeriFactu-native" ERP but connecting the existing ERP to a VeriFactu adapter. An adapter intercepts issued invoices, generates the chained registry with SHA-256 hash, signs it with XAdES when the mode requires it, stamps the QR on the invoice PDF and submits the registry to the AEAT web service in XML format compliant with Order HAC/1177/2024.
The typical integration paths are three, and they coexist without friction:
Dokuflex deploys this architecture on top of SAP, Sage 50/200/X3, A3 (Wolters Kluwer), Holded, Dynamics 365, Navision, Odoo and custom ERPs. Average time-to-production: 48 hours. Check the integration details on the Dokuflex VeriFactu adapter page.
The most common questions about the VeriFactu calendar, the deferral and the obligation.
Yes. RD 254/2025 deferred the original dates of RD 1007/2023. The new mandatory dates are 1 January 2027 for corporate income tax payers and 1 July 2027 for self-employed and the remaining SMEs.
Not necessarily. You can comply with VeriFactu through an adapter that connects to your existing ERP (SAP, Sage, A3, Holded, Dynamics, etc.) via CSV, XML or API. The adapter generates the chained SHA-256 hash, the XAdES signature and the tax QR without touching your current system.
SII (Immediate Supply of Information) is the obligation to submit VAT book records in near-real time. It applies to large companies, VAT groups and entities registered with REDEME. VeriFactu is the chained invoice registry system with SHA-256 hash, tax QR and submission to the AEAT, defined by RD 1007/2023. Companies under SII are exempt from VeriFactu.
If you issue invoices and are not included in SII, you must use a system compliant with RD 1007/2023 from 1 July 2027. You can choose VeriFactu mode (real-time submission to the AEAT) or non-VeriFactu mode (local registry with XAdES signature). For low volumes the VeriFactu mode is usually more practical.
Spanish Law 11/2021 (article 201 bis of the General Tax Law) sets penalties of up to EUR 50,000 per fiscal year for users of non-certified systems, and up to 2% of invoiced amounts in related cases. Manufacturers of non-compliant software face fines of EUR 1,000 per marketed unit. General information. For specific cases consult your Spanish tax advisor.
Yes. Dokuflex generates the chained invoicing registry with SHA-256 hash, XAdES signature, tax QR and automatic submission to the AEAT in VeriFactu mode, compliant with RD 1007/2023 and Order HAC/1177/2024. It works as an adapter on top of your existing ERP without forcing a migration.
In VeriFactu mode, the XAdES electronic signature is not mandatory because the real-time submission to the AEAT acts as an equivalent integrity mechanism. In non-VeriFactu mode, the XAdES signature is mandatory on each invoice registry to guarantee unalterability.
Yes. RD 1007/2023 allows switching between modes, but the change must be documented and held throughout the relevant fiscal year. Dokuflex supports both modes with no migration required. We recommend consulting your tax advisor before switching to avoid AEAT incidents.
All legal and technical statements in this guide come from the following official sources:
YMYL disclaimer: This guide reflects interpretations of public Spanish regulation in force on 14 May 2026 and does not constitute individualised tax or legal advice. For specific cases consult your Spanish tax advisor or a qualified professional. Dates and thresholds may be amended by subsequent royal decrees.
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