With the reference date of September 8, 2026, the implementation of VeriFactu is approaching and raising many questions. One of the most frequent comes from sole traders who pay taxes under the objective estimation scheme, better known as "módulos." Are they really required to adopt a verifiable invoicing system?
The short answer is that, in practice, the vast majority will have to. Below, we break down why.
The Key: The Obligation to Issue Invoices
The VeriFactu Regulation (Royal Decree 1007/2023) does not distinguish between tax schemes (direct estimation or 'módulos'). Instead, it focuses on the obligation to issue invoices. The rule states that all businesses and professionals subject to Personal Income Tax (IRPF) or Corporate Tax must use invoicing software that meets VeriFactu requirements to issue their invoices.
This means the relevant question isn't whether you are on the 'módulos' scheme, but whether you issue invoices. And this is where the main distinction lies.
When Must a Freelancer on 'Módulos' Issue a VeriFactu Invoice?
Many freelancers on the 'módulos' scheme primarily work with private individuals, to whom they usually provide simplified invoices (receipts or 'tiques'). However, the law requires them to issue a full, detailed invoice in the following cases:
- When the client is another business or professional.
- When a private individual client specifically requests it to exercise a tax right.
- For exports or intra-community deliveries.
As soon as a freelancer on 'módulos' needs to issue a single full invoice to another company or freelancer, it must be generated through a VeriFactu system. Since it's very common to have at least one professional client, the need to adapt is nearly universal. For more details, you can check our guide on VeriFactu for Freelancers in Modules (Objective Estimation).
Preparing for the VeriFactu Transition
The deadline for compliance is clear: freelancers and SMEs with a turnover of less than €8 million must have their invoicing systems adapted by July 1, 2027.
Adapting means choosing software that guarantees compliance. This involves having a reliable VeriFactu software gateway or a robust VeriFactu ERP integration. For those already using other systems, the challenge will be to plan how to import Factusol to VeriFactu or migrate data from Sage 50 or Holded. Even the task to import Excel to VeriFactu will require a certified system to process that information, as Excel alone will not be compliant. If you want a better understanding of the system, we recommend reading What is VeriFactu? Guide for Freelancers in Spain.
In summary, although the 'módulos' scheme simplifies tax calculation, it does not exempt you from invoicing obligations. Being proactive and adopting a compliant solution is the smartest strategy to avoid issues and penalties.
At Fakturia.es, we offer invoicing software that is 100% compliant with VeriFactu regulations and the Anti-Fraud Law, designed to help freelancers and SMEs comply with the law easily and securely.