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Resolve Your Doubts: Frequently Asked Questions on Veri*factu and Electronic Invoicing

Adapt your invoicing to Veri*factu and comply with the AEAT seamlessly. Here you will find clear answers regarding requirements, deadlines, and procedures so you can make decisions with confidence.

Written by Sandra Álvarez
Updated over 3 months ago

Start with the essentials and act today

Veri*factu is part of the AEAT’s anti-fraud strategy and requires invoices to be complete, unalterable, and, in many cases, automatically submitted. Once an invoice is issued, it cannot be modified or deleted. Furthermore, from 29 July 2025, only software adapted to the RRSIF and compatible with Verifactu may be marketed.

Frequently Asked Questions

1. Can I modify an invoice once it has been issued?

No. According to Article 8 of Royal Decree 1007/2023, invoicing systems must ensure the integrity and immutability of records. Any subsequent modification must be made via the issuance of a corrective invoice, as it is not permitted to delete, conceal, or alter any record once it has been generated.

2. Can I issue an invoice with a date prior to its actual issuance?

The regulation distinguishes between the invoice issue date, i.e., the actual moment the invoice is issued, and the transaction date, i.e., when the service is actually provided or the taxable event occurs. According to Article 10 of RD 1007/2023 and Article 6 of RD 1619/2012, both dates must be indicated if they do not coincide. The issue date must always reflect the actual issuance date, while the transaction date may refer to an earlier time. Backdating the issue date to simulate earlier issuance is not allowed.

3. Must the invoice issue date match the date of registration in the system?

Yes. The invoice issue date must match the registration date in the SIF, in accordance with Article 10 of the RRSIF and Article 6 of RD 1619/2012. The transaction date may differ and must be recorded if the delivery of goods or provision of services occurred on a different date.

4. Can I issue a receipt without generating an invoice?

Generally, no. Every professional or business must issue an invoice for their transactions. Only in certain specific schemes is this obligation waived. In all other cases, Article 26 of RD 1619/2012 establishes that every transaction performed by a professional or business must be accompanied by an invoice. A receipt may complement the documentation but does not replace the obligation to issue an invoice.

5. Can I issue an invoice in the name of the owner or tourist even if they are not the service provider?

Yes, it is possible to issue an invoice on behalf of a third party, provided the legal conditions of Article 5 of RD 1619/2012 are met: invoicing by third parties or self-invoicing, with prior written agreement, acceptance procedure by the principal, and forwarding a copy to the actual provider. Issuing in the name of someone not acting as the taxable person is only allowed with a valid express mandate.

6. Can I issue an invoice that groups several bookings or transactions?

Yes. Article 13 of RD 1619/2012 allows for summary invoices that group multiple transactions for the same recipient within the same calendar month. Deadlines: last day of the month if the recipient is a private individual; before the 16th of the following month if the recipient is a business or professional.

7. Is it possible to implement a pre-invoicing or draft system?

Yes, provided this environment does not generate formally issued invoices or record tax operations definitively. Actual issuance must occur from a SIF adapted to the RRSIF.

8. When is the submission of invoices via Veri*factu mandatory?

For legal entities, from 1 January 2027. For individuals, from 1 July 2027. From 29 July 2025, all new software marketed must be RRSIF-adapted and Veri*factu compatible.

9. Can a client continue using our system if invoices are issued in it but submitted to the AEAT from another SII-connected system?

It depends on whether the system is considered a SIF. If it generates invoices with fiscal effect, it must comply with the RRSIF, regardless of whether submission occurs through another system. Only if it produces proposals or drafts could it fall outside the scope. This point awaits official confirmation from Veri*factu.

10. Can a client not obliged to issue invoices (for declaring only real estate income) generate payment receipts?

Yes, provided these receipts do not resemble an invoice, do not include tax terminology or equivalent numbering, and are not used for improper tax purposes. This point is pending official confirmation from the Veri*factu system. Currently, our system does not allow this issuance; it is under development and will be announced when available.

11. Can we offer non-approved versions of our systems until 2026?

No. From 29 July 2025, all products marketed must be adapted. Users of previous versions may continue using them until their obligation deadline.

12. How should disbursements, financial surcharges, or withholding tax be reflected on the invoice?

They are not part of the “total invoice amount” in the Veri*factu record or tax QR, though they may be shown on the invoice for customer information. It is recommended to clearly itemise them (e.g., total invoice, withholding, and total payable).

13. Where can I consult my issued invoices?

On the AEAT portal under “Consulta de registros de facturación”. Identify yourself with an electronic certificate/DNIe or Cl@ve Móvil, complete the filters (NIF, period, recipient NIF, series, invoice number), and search to view submitted records.

14. Legal basis for question 9 (using one system for issuing and another for SII submission)

Article 2 of RD 1007/2023 defines a SIF as any system that allows the issuance of invoices or simplified invoices. If the system issues invoices with fiscal effect (Article 6 of RD 1619/2012), it must comply with the RRSIF, even if submission to the SII occurs through another system. The obligation arises at issuance, not at accounting transmission. The AEAT has indicated in technical forums that submission via other channels does not exempt compliance in the originating system, in line with the RRSIF traceability principle.


Annex: Legal Basis

Basis for question 9 (issuing in one system and submitting from another)

A SIF is any system that allows invoice issuance. If the system issues documents with fiscal effect, it must comply with the RRSIF regardless of the submission channel (traceability principle). The obligation arises at issuance, not accounting transmission.

Basis for question 10 (receipts for those not obliged to invoice)

Those who receive only real estate income and do not conduct economic activity are not obliged to issue invoices and may document payment with a receipt that does not resemble or function as an invoice, in accordance with administrative doctrine and the economic reality principle.

Glossary

  • SII (Immediate Information Supply of VAT): AEAT system for near real-time electronic submission of the ledgers of certain taxpayers; does not regulate invoice issuance.

  • SIF (Invoicing Information System): Software that issues invoices or simplified invoices and must ensure integrity, preservation, traceability, and invoicing records; may operate in Veri*factu mode.

  • RRSIF (Regulations on the Requirements of Invoicing Information Systems - RD 1007/2023): Sets technical obligations such as immutability, preservation, traceability, and record-keeping; introduces Veri*factu mode.

  • Self-invoicing: Mode in which the recipient issues the invoice on behalf of the supplier, with prior agreement and acceptance. Does not alter the supplier’s tax responsibility.

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