28/11/2025
Dear Clients,
At ROGNER ADVISORS , we would like to inform you that, in accordance with the new Regulation on Requirements for Billing Systems and Software (SIF), taxpayers will be required to adapt to the VERIFACTU system, which involves the automatic generation and transmission of billing records to the Spanish Tax Agency (AEAT).
This means that billing software applications must include a responsible declaration confirming that they comply with the requirements established in the Regulation for billing software solutions and that they meet the specifications approved in the Ministerial Order. Penalties for non-compliance established by the AEAT are very substantial.
Billing software may fall into two categories:
VERIFACTU, which will immediately send the information to the AEAT and will generate a verification QR code.
NON-VERIFACTU, which will not generate a QR code and will require the taxpayer to keep and store the records for the legally established time periods.
Regarding when Verifactu becomes mandatory, Royal Decree 254/2025 of April 1st has amended the 2023 Regulation and established the following implementation dates:
From January 1st, 2026: for Corporate Income Tax (Impuesto sobre Sociedades) taxpayers.
From July 1st, 2026: for Personal Income Tax (IRPF) taxpayers with economic activity, Non-Resident Income Tax (IRNR) taxpayers with economic activity, and entities under the income attribution regime.
The following will be required to comply with this system:
Self-employed individuals and companies: anyone who issues invoices using certified billing software.
Taxpayers: Corporate Income Tax payers (with some exceptions), IRPF taxpayers carrying out economic activities, and Non-Resident Income Tax taxpayers operating through a permanent establishment.
Entities under the income attribution regime that carry out economic activities.
However, this project will not apply to:
Taxpayers in Foral territories (Navarra, País Vasco), which have their own systems.
Companies already included in the SII system (Immediate Information System).
Operations exempt from the obligation to issue an invoice.
Retail sales: operations with final consumers where no invoice is issued (only ticket or simplified record).
Professions that do not issue invoices, such as certain artistic or sports activities, when they are not required to issue invoices.
Certain financial and insurance operations that are VAT-exempt.
Special VAT regimes:
a. Simplified regime (modules)
b. Special regime for Agriculture, Livestock and Fisheries (REAGP)
c. Retailer’s equivalence surcharge
Some cases of self-billing, particularly those where the customer issues invoices on behalf of the supplier under an agreement (art. 5 Billing Regulation), provided that the customer is in the SII.
Taxpayers who obtain an exemption from the AEAT’s Department of Management.
It is essential to understand that this exemption applies only if all operations fall under these categories. If, occasionally, a transaction requires a standard invoice (for example, to another professional or company), then for that specific operation the taxpayer must comply with the record-keeping obligations and therefore with VERIFACTU.
To facilitate adaptation to this new regulation, ROGNER ADVISORS SL will provide clients with the ERPLoop tool, a multilingual platform that allows issuing invoices fully compliant with all VERIFACTU requirements, without installing or purchasing any additional invoicing software.
We invite you to contact our team at ROGNER ADVISORS for more information on the adaptation process and to clarify any questions you may have.
The team at ROGNER ADVISORS remains at your disposal.
[email protected]
