The penalty regime · LGT

VeriFactu penalties

€50,000 per
fiscal year

Art. 201 bis of the General Tax Law fines the use of non-compliant invoicing software with €50,000 per fiscal year. The amount doesn't depend on your company's size.

Same amount for a self-employed person as for an SL
The antidote

Compliant from the first record. Penalty risk: €0.

Cofactu is software compliant with RD 1007/2023: every invoice is signed, chained with a SHA-256 hash and verifiable by the AEAT itself. As long as you invoice with Cofactu, there's no art. 201 bis infraction to commit.

Regime set out in official regulation
Art. 201 bis LGT Ley 11/2021 · Antifraude RD 1007/2023 · VeriFactu Orden HAC/1177/2024 AEAT
Self-employed · SL · SA · manufacturer

A single amount, for every taxpayer

Art. 201 bis LGT sets €50,000 per fiscal year for the user of non-compliant software and €150,000 per fiscal year and system type for the manufacturer. In both cases the amount is fixed and isn't scaled by revenue. Complying with Cofactu costs from €0/year with the Free plan: the potential fine is €50,000 per fiscal year.

Penalty table · art. 201 bis LGT
Infraction Offending party Penalty
Use or possession of invoicing software non-compliant with VeriFactu
Business owner / professional user of the software (self-employed, SL, SA, etc.) €50,000 / fiscal year
Production, marketing or distribution of non-compliant invoicing software
Manufacturer / developer / distributor of the software €150,000 / fiscal year / type
Software with dual-use mechanisms (allows keeping "off the books" accounting)
Manufacturer and/or user Additional, cumulative

Source: art. 201 bis Ley 58/2003 General Tributaria, introduced by Ley 11/2021 (Antifraud Law). Informational only — not tax advice.

In perspective

Why the fixed amount matters

The regime isn't scaled. These three traits explain why your exposure is the same as any other taxpayer's.

01

No scaling by size

Art. 201 bis LGT doesn't reduce the amount for small businesses, micro-businesses or the self-employed. A self-employed worker issuing 10 invoices a year has the same exposure as a mid-sized company.

02

Accumulates per fiscal year

If you use non-compliant software for 3 fiscal years, the penalty applies for each one. The possible accumulation reaches €150,000 for the user.

03

Doesn't depend on invoice count

The infraction is for holding or using the software, not for each invoice. Issuing 1 or 10,000 invoices during a fiscal year carries the same regime.

Exposure calculator

Rough estimate. Not tax advice.

Estimated fine

€50,000

1 fiscal year × €50,000/fiscal year (art. 201 bis LGT)

Cofactu · same period

Free plan · VeriFactu invoicing free forever

€0

Complying with VeriFactu on Cofactu's Free plan costs €0. The fine, up to €50,000 per fiscal year.

Notice: for guidance only. Amounts based on art. 201 bis LGT. Not tax or legal advice.

Literal text of the law
"The holding of computer systems or programs that do not conform to what is required shall be sanctioned with a fixed fine of €50,000 per fiscal year."
BOE

Art. 201 bis

Ley 58/2003 General Tributaria

The math is simple

€50,000 of risk. €0/month of insurance.

Start for free

€50,000

Fine for the user

Per fiscal year with non-compliant software. Fixed, no scaling by size.

€150,000

Fine for the manufacturer

Per fiscal year and system type for whoever produces or markets the software.

€0

Cost to comply

Cofactu complies with VeriFactu from €0/month with the Free plan, free forever. Against a €50,000 fine, the math is clear.

FAQ

Frequently asked questions about VeriFactu penalties

How much is the penalty for using non-compliant VeriFactu software?
Art. 201 bis of the General Tax Law sets 50,000 euros per fiscal year for the user who holds or uses non-compliant invoicing software. The amount is fixed: the same for a self-employed worker issuing 3 invoices a month as for a company with a hundred employees.
Is the 50,000 € penalty per fiscal year or per invoice?
It's per fiscal year. If you use non-compliant software for 3 full fiscal years before fixing it, the potential accumulated penalty would be 150,000 euros. It doesn't depend on the number of invoices issued.
Do the penalties also apply to software manufacturers?
Yes, and with higher amounts. Art. 201 bis LGT sets 150,000 euros per fiscal year and system type for manufacturers, developers and distributors of non-compliant invoicing software.
Can I avoid the penalty if I had old software and update it before the deadline?
Yes. The penalty applies for holding or using non-compliant software from the obligation date onward. If you update your software before January 1, 2027 (corporations) or July 1, 2027 (self-employed), you don't incur an infraction. The deadline is an adaptation window — use it.
Is the penalty scaled by company size?
No. Art. 201 bis LGT sets a single amount of 50,000 euros per fiscal year regardless of revenue, number of employees or business size. It's one of the most striking features of this penalty regime.

€50,000 at risk. Complying with Cofactu costs €0/month.

The Free plan complies with VeriFactu for €0/year, free forever. The fine for non-compliance is €50,000 per year. The math is clear.