To choose invoicing software before paying, you must verify ten key criteria: developer responsible declaration regarding VeriFactu, compatibility with B2B electronic invoicing, QR code generation with SHA-256 hash footprint, personal income tax withholding calculation, applicable VAT rates, export for tax models, unalterable cancellation records, and guaranteed legal support.
Legal criteria: VeriFactu, SHA-256 and responsible declaration
Royal Decree 1007/2023 and Order HAC/1177/2024 establish mandatory technical specifications for any computerized invoicing system in Spain. The legal foundation stems from article 29.2.j) of the General Tax Law, introduced by Law 11/2021 on measures to prevent and combat tax fraud.
- Developer responsible declaration versus false certifications: the Spanish Tax Agency (AEAT) does not approve, certify, or register software tools in any official register. All commercialized software must mandatorily include a responsible declaration signed by the developer. Anyone marketing their application as «approved by the Tax Agency» is lying and breaching current regulations.
2. Traceability via chained SHA-256 cryptographic hash: each billing entry must generate an invoice record or a cancellation record containing a SHA-256 hash mathematically linked to the immediately preceding record. This mechanism ensures the immutability of generated invoices and prevents any hidden deletion or parallel accounting.
3. Inclusion of QR codes and standardized records: the software must print on every issued document a structured QR code according to the standards of Order HAC/1177/2024. This code enables the recipient to verify record validity directly through the tax administration's electronic portal.
Choosing VeriFactu software for freelancers that complies with these three points prevents penalties under article 201 bis of the General Tax Law: €50,000 for the user per fiscal year using non-compliant systems and €150,000 for the developer per fiscal year and program type sold, plus €1,000 per program marketed without a responsible declaration.
Data exchange criteria: B2B electronic invoicing and Crea y Crece Law
Law 18/2022 on the creation and growth of companies regulates mandatory issuance and receipt of electronic invoices strictly between businesses and professionals. This obligation does not replace VeriFactu, but coexists with it simultaneously and independently in daily operations.
4. Technical differentiation between VeriFactu and B2B electronic invoicing: VeriFactu oversees billing software and the transmission of billing records to AEAT; conversely, B2B regulations determine standardized documentary exchange formats between commercial suppliers and corporate buyers.
5. Tracking payment and acceptance statuses within 4 calendar days: the platform must support reporting and receiving invoice statuses (accepted, rejected, and paid) within a maximum of 4 calendar days from the commercial event. Mandatory electronic invoicing for freelancers now has fixed dates: Order HAC/1028/2026 entered into force on October 6, 2026, so it applies from October 6, 2027 to companies with over 8 million euros in annual turnover and from October 6, 2028 to all remaining enterprises and sole traders (final dates, BOE).
Tax criteria: VAT calculation and personal income tax withholding
Article 4 of Royal Decree 1619/2012 provides that simplified invoices can only be issued for operations up to €400 including VAT, or up to €3,000 in specific authorized retail sectors. The software you select must distinguish these transactions from complete ordinary invoices.
6. Calculation of applicable VAT rates: the system must compute with mathematical precision the standard 21% rate, reduced 10% rate, or super-reduced 4% rate, properly itemizing the taxable base and resulting tax liability.
7. Automated invoice withholdings: independent professionals must apply a 15% income tax withholding under article 95.1 of the IRPF Regulation when billing companies, other sole traders, or homeowners associations. For new freelancers, the rate is 7% during the launch year and the following two years after notifying the client in writing. Commercial property leases carry 19%, agricultural and livestock activities 2%, and pig fattening or poultry farming 1%.
| Invoice item | Calculation | Amount |
|---|---|---|
| Taxable base | professional service fees | 1.000,00 € |
| VAT (21 %) | 1.000,00 € × 21 % | 210,00 € |
| Income tax withholding (15 %) | 1.000,00 € × 15 % | −150,00 € |
| Total invoice (base + VAT) | 1.000,00 € + 210,00 € | 1.210,00 € |
| Receivable payout | total − withholding | 1.060,00 € |
Sales to individual consumers do not carry income tax withholdings, and commercial corporations billing services to other corporations do not apply this deduction either. The withholding client remits these amounts through quarterly modelo 111 and itemizes them in annual modelo 190 under code G01 (15%) or G03 (7%).
8. Structured generation of periodic tax returns: the program must generate structured reports aligned with quarterly VAT return modelo 303 (submitted between April 1–20, July, October, and January 1–30) and annual modelo 390. For personal income tax, it must compile calculations for modelo 130 at 20% of net profit under direct estimation or 2% for agricultural activities, while identifying third-party operations exceeding €3,005.06 annually for February's modelo 347.
Functional criteria: legal timeline and operational availability
The deadline for software developers expired on July 29, 2025, exactly nine months after Order HAC/1177/2024 entered into force. End users face phased enforcement dates: January 1, 2027 for Corporate Income Tax taxpayers and July 1, 2027 for sole traders, joint-ownership entities, and civil partnerships.
9. Regional compliance rules and exclusions: software must accommodate local territorial rules. Entities under the Immediate Supply of Information (SII), taxpayers in the Basque Country and Navarra under TicketBAI, and those invoicing manually on paper are excluded from VeriFactu. Conversely, professionals in the Canary Islands, Ceuta, and Melilla must fully comply with VeriFactu.
10. Cloud technical infrastructure and language interfaces: the solution must ensure secure browser access without local data loss risks, offering official Spanish state languages such as Spanish, Catalan, or Galician alongside English, and maintaining continuous automated backups ready for tax audits.
Frequently asked questions
Does the Spanish Tax Agency publish a list of approved software?
The Spanish Tax Agency does not homologate or certify any commercial invoicing software. Legal compliance with Royal Decree 1007/2023 is demonstrated exclusively through the formal responsible declaration issued directly by the software developer.
What happens if a freelancer uses non-adapted software in 2027?
Article 201 bis of the General Tax Law establishes a fixed penalty of €50,000 per fiscal year for possessing non-compliant systems. This fine automatically penalizes any business user operating billing tools unadapted to VeriFactu.
When is electronic invoicing mandatory compared to VeriFactu?
VeriFactu becomes mandatory on January 1, 2027 for corporations and on July 1, 2027 for freelancers. B2B electronic invoicing becomes mandatory on October 6, 2027 if your turnover exceeds €8 million and on October 6, 2028 otherwise (Order HAC/1028/2026).
Must simplified invoices satisfy the exact same technical rules?
Simplified invoices issued up to €400 or €3,000 must incorporate SHA-256 chaining and the official QR code. Any electronic record generated by the billing system falls strictly under the requirements of Royal Decree 1007/2023.
Before purchasing an IT tool for your business, assess the technical compliance of your current setup by completing Fakturia's free VeriFactu diagnosis in just two minutes.