Invoicing with Excel and Word:
what the regulation actually says
Neither Royal Decree 1007/2023 nor the Anti-Fraud Law bans Excel or Word by name. What they require is that the system you issue your invoices with meets a very specific set of conditions. Here is why an editable template does not meet them, and from when that affects you.
Why doesn't a template comply?
- Direct manipulation: Figures, descriptions and dates can be changed or deleted at any time without leaving a trace — the opposite of the unalterability the regulation demands.
- No SHA-256 chaining: There is no encrypted sequential record guaranteeing that invoice 2 was created after invoice 1 in a way that cannot be altered.
- Nobody signs the responsible declaration: The Spanish Tax Agency does not approve or certify invoicing software. What the regulation requires is that the manufacturer of the system signs a responsible declaration (declaración responsable) stating that it complies — and neither Microsoft nor Google sells Excel or Sheets as an invoicing system, so there is nobody to sign one for your template.
The Mandatory Technical Requirements
- Unalterability: Once an invoice has been saved, its data cannot be modified under any circumstances.
- Traceability: Any correction must generate a new document linked to the previous one.
- Retention: The software must guarantee secure storage for a minimum of 4 years.
- Readability: The data must be available in a standard structured format for quick export.
Comparison Table: Template vs Compliant System
| Feature | Excel / Word (Template) | Fakturia (VeriFactu) |
|---|---|---|
| Complies with Royal Decree 1007/2023? | No (guarantees neither unalterability nor traceability) | Yes (with the manufacturer's responsible declaration) |
| Mandatory AEAT QR code | Not available (impossible to generate automatically) | Generated automatically in the PDF |
| SHA-256 chaining | No (files are independent and can be altered) | Yes (an unbreakable mathematical chain) |
| Flat €50,000 fine per financial year | A real risk once your deadline arrives (2027) | Zero |
Dual-use software
Law 11/2021 on measures to prevent and combat tax fraud targets the possession and use of software that makes it possible to hide sales or keep a second set of books (so-called dual-use software). That is where the requirement comes from: an invoicing system must produce complete, traceable and unalterable records. A spreadsheet, where any cell can be changed without leaving an audit trail, is unlikely to be able to show that it meets it.
Frequently Asked Questions (FAQ)
Can I fill in the Excel file and save it as a non-editable PDF?
It does not solve the problem. Even though the PDF your client receives cannot be edited, the system you generated the invoice with is still the spreadsheet, and there is no chained billing record or SHA-256 hash in it. The regulation looks at the system that issues the invoice, not at the format of the file you send.
Are there fines for a freelancer who uses Excel?
Not for using Excel: for invoicing with a non-compliant system once your deadline has arrived. Article 201 bis of the Spanish General Tax Law sets a fine of €50,000 per financial year for the user. It is not "up to" €50,000: the amount is fixed.
So can I keep invoicing with Excel in 2026?
Yes. For the user there is no prohibition until 1 January 2027 if you pay Corporate Income Tax, or until 1 July 2027 in every other case. What you should not do is leave it to the last week: migrating clients, history and invoice numbering calmly works far better than doing it against the clock.
Leave Excel behind in good time. Move to the VeriFactu standard.
Fakturia.es makes issuing invoices as simple as filling in a spreadsheet, but with chained records, QR codes and submission to the Spanish Tax Agency: what the regulation asks for and a template cannot deliver.