A chained invoicing record
Every invoice creates a record that carries the fingerprint (hash) of the previous one. If someone deletes or changes an invoice, the chain shows it. Mistakes are fixed with a new record, never by rewriting the old one.
VeriFactu · International groups VeriFactu for
Does it apply to you? ↓ VeriFactu for
foreign companies
VeriFactu applies to the Spanish subsidiary and to the branch or permanent establishment of a foreign group that invoice with software, unless they are on the SII or taxed in the Basque Country or Navarre.
Companies, before 1 January 2027. Branches and permanent establishments, before 1 July 2027. General information; not tax advice.
| Situation in Spain | Does it apply? | Why | Deadline |
|---|---|---|---|
| Spanish subsidiary (SL or SA)01 | Yes | It is a Spanish company and pays Corporate Income Tax (art. 3.1.a of Royal Decree 1007/2023). Foreign ownership changes nothing. | DeadlineBefore 1 January 2027. |
| Branch or permanent establishment02 | Yes | The foreign company pays Non-Resident Income Tax in Spain through a permanent establishment (art. 3.1.c). The AEAT confirms it in its FAQ. | DeadlineBefore 1 July 2027. |
| Foreign company with no establishment03 | Not listed | Art. 3.1 does not include it among those obliged, and the AEAT only answers yes for a non-resident with a permanent establishment. There is no written exclusion either: confirm your case with an adviser. | DeadlineThe regulation sets no date for it. |
| Group company under the SII04 | No | A company that keeps its VAT books through the SII is outside the regulation (art. 3.3). The AEAT looks at each company on its own, not at the group. | DeadlineIt stays on the SII. |
What it requires Four pieces
Four pieces
in every Spanish invoice
A QR code on the invoice
Every invoice from the system carries a tax QR code. If the system sends its records to the AEAT, the invoice also shows the phrase “VERI*FACTU”, and the customer can check it on the AEAT website.
The software's statement of conformity
The producer of the system signs it (art. 13 of Royal Decree 1007/2023): it identifies the system, its version, how it is built and the rules it declares it meets, and it must be visible to the customer. It is not an AEAT approval.
Send to the AEAT, or keep without sending
With submission (VERI*FACTU), each record goes to the AEAT as the invoice is issued. Without it, the system signs every record and keeps an event log: that is valid too, but you must keep everything and be able to prove it has not been altered.
Out of scope Who does not have to
Who does not have to
comply with VeriFactu?
Five cases in which the regulation does not apply, or it is not clear that it does. Each company in the group is reviewed separately.
- 01 SII Immediate Supply of Information. A company that keeps its VAT books through the SII does not apply the regulation (art. 3.3). In a group, each company is assessed separately: one subsidiary can be on the SII and another not.
- 02 Basque Country and Navarre Regional (foral) tax rules. Taxpayers under the regional rules use TicketBAI in the Basque Country or Navarre's own system. With a tax address in the rest of Spain, though, the regulation does apply (art. 1.3).
- 03 No establishment A case to confirm. The regulation does not mention a foreign company that invoices in Spain with no permanent establishment. It is not an express exclusion: check your case with an adviser before ruling it out.
- 04 Establishments abroad Art. 4.2. Invoices for transactions made through permanent establishments located outside Spain are excluded. If your Spanish subsidiary has a branch in another country, those invoices do not follow VeriFactu.
- 05 Handwritten invoices No computer system. With no invoicing software it does not apply, although the general invoicing rules (Royal Decree 1619/2012) still do.
What's the
VeriFactu deadline?
Royal Decree-law 15/2025 pushed the deadlines of Royal Decree 1007/2023 back by a year. The date depends on the tax each entity pays in Spain, not on the group.
| Who | Article of RD 1007/2023 | Date |
|---|---|---|
| Spanish subsidiary · Corporate Income Tax | Art. 3.1.a | Before 1 January 2027 |
| Branch or permanent establishment · Non-Resident Income Tax | Art. 3.1.c | Before 1 July 2027 |
| Self-employed and income-attribution entities | Art. 3.1.b and d | Before 1 July 2027 |
| Software producers and resellers | Art. 3.2 | Compliant products since 29 July 2025 |
General information; not tax advice.
Penalties A fixed fine:
A fixed fine:
€50,000 per year.
Article 201 bis of the General Tax Law fines the holder of non-compliant invoicing software €50,000 per financial year, and whoever makes or sells it €150,000 per financial year and type of system. The amount does not depend on the size of the company or the number of invoices.
How the penalties work →
Can your global ERP
be VeriFactu compliant?
The ERP complies on its own
If your ERP vendor offers a module for Spain that creates the record, the QR code and the submission, ask for the statement of conformity for the version you run. Without it you cannot tell what it declares to meet.
A compliant component
An add-on or middleware service takes the invoice from the ERP, creates the chained record and the QR code and sends it to the AEAT. For the regulation, the invoicing system is that whole chain (art. 1.2), and its statement of conformity describes how it is built.
A separate invoicing system
The Spanish entity invoices from a compliant system, with its own statement of conformity, connected to the group ERP through an API. The ERP stays the core system; the Spanish invoice comes from the system that complies.
Each company's system meets that company's own obligations,
even when the group shares one ERP (AEAT FAQ).
The separate system,
ready for the Spanish entity
Cofactu invoices for Spain: it creates the chained record and the QR code for every invoice and sends it to the AEAT. It is included in every plan, Free too.
To connect it to the group ERP there is an API: everything the app does, the API does, included from the SME plan (on Free, with the Dispatch add-on). There is no dedicated connector for SAP or Dynamics: the integration is built against the API.
Frequently asked questions
about VeriFactu for foreign companies
Is VeriFactu mandatory? → Does VeriFactu apply to foreign companies?
It depends on how they operate in Spain. It applies to a Spanish subsidiary, which pays Corporate Income Tax, and to the branch or permanent establishment of a foreign company, which pays Non-Resident Income Tax, as long as they invoice with software, are not on the SII and have their tax address outside the Basque Country and Navarre. The regulation does not mention a foreign company with no permanent establishment: confirm that case with an adviser.
Do I need VeriFactu for my Spanish subsidiary?
Yes, if it invoices with a computer system, does not keep its VAT books through the SII and is not taxed under the regional rules of the Basque Country or Navarre. As a Corporate Income Tax payer it must be ready before 1 January 2027. The AEAT assesses each company in the group separately.
Does a branch or permanent establishment in Spain have to comply with VeriFactu?
Yes. The AEAT states in its FAQ that invoices from a non-resident business are covered when it has a permanent establishment. As a Non-Resident Income Tax payer, its deadline is the one for all other taxpayers: before 1 July 2027.
Can my global ERP be VeriFactu compliant?
Yes, if the system that issues the Spanish invoice complies. For the regulation, the invoicing system is the set of hardware and software that issues it, so there are three routes: a module of the ERP itself with its statement of conformity, a middleware component that creates the record, the QR code and the submission, or a separate invoicing system connected to the ERP through an API.
What's the VeriFactu deadline?
Following Royal Decree-law 15/2025, before 1 January 2027 for Corporate Income Tax payers and before 1 July 2027 for all other taxpayers, including branches and permanent establishments of foreign companies. Software producers have had to offer compliant products since 29 July 2025.
Do invoices have to be sent to the AEAT?
It is not mandatory. The system can send each record to the AEAT as it issues the invoice (the VERI*FACTU mode, with the phrase printed on the invoice) or keep the records without sending them, signing each one and keeping an event log. Both comply; the second means you must later be able to prove that what you kept has not been altered.
What is the penalty for not complying with VeriFactu?
Article 201 bis of the General Tax Law sets a fine of €50,000 per financial year for the user who holds non-compliant invoicing software, and €150,000 per financial year and type of system for whoever makes or sells it. It does not depend on turnover or on the number of invoices.
Are companies on the SII or in the Basque Country and Navarre out of scope?
Yes. A company that keeps its VAT books through the SII does not apply the regulation, and one taxed under the regional rules uses TicketBAI in the Basque Country or Navarre's own system. In a group, each company is assessed separately: one subsidiary can be on the SII and another not.
