Is It Legal to Invoice Without Software?
Your options under VeriFactu
Many freelancers wonder whether they are required to pay for an invoicing program or whether they can keep issuing invoices entirely by hand. Here are the limits the law actually sets.
Handwritten Paper Invoicing
The only 100% legal way to invoice without software is to write your invoices by hand, using official paper invoice books from an authorised printer.
- ✓You use no computers, no phones and no printers.
- ✓Only advisable for freelancers with an extremely low invoicing volume.
What Counts as Software?
Any computer or digital device involved in creating the receipt or invoice is classed as software by the Tax Agency.
- ✗Excel or Word templates edited on a computer: they are not banned, but they count as an invoicing system and therefore have to meet the regulation.
- ✗Traditional cash registers not adapted to VeriFactu.
The risk of hybrid invoicing
Many freelancers wrongly assume that drafting invoices in Word, saving them as PDFs and printing them on paper counts as "invoicing without software". That is not the case.
Once a word processor or a digital editor has been used to format and print the document, you are running a computerised invoicing system. From your compliance date —1 January 2027 if you pay corporate income tax, 1 July 2027 for everyone else— that system must meet the SHA-256 chaining and tamper-proofing requirements of the Anti-Fraud Law. Using one that does not is a serious infringement carrying a fixed fine of €50,000 per financial year.
Frequently Asked Questions
Is there an official free alternative?
Yes, and it is already up and running: the AEAT (the Spanish Tax Agency) has had its free VERI*FACTU app live since October 2025. It does, however, lack automated integrations, digitised expense archiving and smart assistants to help you prepare your tax returns.
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