The Veri*factu system is part of a new strategy by the State Agency of Tax Administration (AEAT) to improve the control and traceability of invoicing. Starting in 2025, invoicing programs must adapt to a series of technical requirements that ensure data integrity, prevent alteration, and, in many cases, allow records to be sent directly to the tax authorities.

These changes may raise many questions, such as: Can an invoice be modified once issued? Is it valid to issue grouped invoices? What about receipts, withholdings, or reimbursements? What happens if a system is not yet approved? This document gathers the most common questions that arise during the transition to this new model, with answers based on current regulations and the interpretative criteria disseminated by the AEAT.

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

No. According to Article 8 of Royal Decree 1007/2023, invoicing software must ensure the integrity and immutability of records. Any subsequent modification must be made by issuing a corrective invoice, as deleting, hiding, or altering any record once generated is not allowed.

2. Can I issue an invoice with a date earlier than its actual issuance?

The regulations distinguish between the issue date of the invoice, which is the actual moment it is issued, and the operation date, which is when the service is actually performed or the taxable event occurs.

According to Article 10 of RD 1007/2023 and Article 6 of RD 1619/2012, the invoice must indicate both fields when they do not coincide. The issue date must always reflect the actual date of issuance, while the operation date can refer to earlier times.

For example, an invoice issued on April 4 can include March 31 as the operation date, as long as the difference is clearly documented and justified in the operation's content.

What is not permissible is backdating the issue date of the invoice to simulate it was issued on an earlier date. That would constitute an improper alteration of the invoicing record and violate the traceability principle required by the RRSIF.

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

Yes. The issue date of the invoice must match the invoicing registration date in the SIF, according to Article 10 of the RRSIF and Article 6 of RD 1619/2012.

However, this date can differ from the operation date, which must be recorded when the delivery of goods or service provision occurred on a different date.

For example, if a user issues an invoice on April 4, that will be the issue date and the registration date. However, the operation date could be March 31 if the service provided took place on that day. Both dates must be included in the corresponding fields.

What cannot be done is issuing an invoice in April and backdating it to March, altering the issue date. This practice is against the regulations and may constitute a violation.

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

Generally, no. Every professional or business must issue an invoice for their operations. Only in certain specific regimes, such as the special regime for agriculture, livestock, and fishing. For all other cases, Article 26 of RD 1619/2012 establishes that every operation carried out by businesses or professionals must be accompanied by an invoice. The receipt can complement the documentation but does not replace the obligation to invoice.

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

Yes, it is possible to issue an invoice in the name of a third party, provided certain legal conditions established in Article 5 of RD 1619/2012 are met. There are two valid figures for this type of issuance:

However, if the intention is to issue an invoice in the name of a person who has not provided the service nor is the holder of the economic activity (for example, an owner who has delegated management to a company), it would not be correct to do so, unless:

For example, it would not be correct for a company that directly provides the service to the customer to issue the invoice in the name of the property owner if the owner is not involved in the operation nor listed as the taxable person. In that case, the invoice should be issued in the name of the providing company itself. On the other hand, if a management company acts on behalf of the owner and issues invoices on their behalf, according to a prior third-party invoicing agreement, then issuing invoices in the owner's name would be allowed.

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

Yes. Article 13 of RD 1619/2012 allows the issuance of recap invoices that group several operations carried out for the same recipient, provided that these operations took place within the same calendar month.

These invoices must be issued:

For example, if the same customer booked services on May 3, 10, and 25, a single recap invoice can be issued with an issuance date of May 31 (or before June 16, if they are a professional).

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

Yes, it is possible, as long as the pre-invoicing system does not generate formally issued invoices or definitively record tax operations.

Royal Decree 1007/2023 and its development regulations only apply to computer systems that generate valid invoices or simplified invoices, with the corresponding legal effects. Preliminary environments, such as drafts, invoice proposals, or simulators, can remain outside the compliance with the RRSIF, provided that the actual issuance of the invoice is done from a system adapted and in accordance with the required technical conditions.

8. When is it mandatory to send invoices through Veri*factu?

The obligation to send invoicing records through Veri*factu systems will apply:

However, the regulations also establish prior obligations for developers and marketers of invoicing programs. From July 29, 2025, all new products offered on the market must be adapted to the technical requirements of the RRSIF and be compatible with the Veri*factu mode.

Therefore, although end users have a longer period to adapt, manufacturers will not be able to market non-certified versions from that date. Additionally, taxpayers with already adapted systems can start sending records voluntarily before the mandatory period begins, if they wish.

9. Can a customer continue using our system if they issue invoices in it but send them to the AEAT from another system connected to the Immediate Supply of VAT Information (SII)?

It depends on whether their system is considered a SIF. If their system generates invoices with tax effects, it is required to comply with the RRSIF, regardless of whether the submission is done from another system.

Only if their system does not generate invoices but proposals or drafts, could it be considered outside the scope of application.

This point is pending official confirmation from Veri*factu. For a more detailed explanation of its normative and interpretative basis, you can consult the normative basis of questions 9 and 10 included in the annex at the end of the document.

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

Yes, it is possible, as long as these receipts:

The use of these documents as payment receipts is allowed in cases where there is no obligation to invoice. However, this point is pending official confirmation from the Veri*factu system.

For a more detailed explanation of its normative and interpretative basis, you can consult the development of questions 8 and 9 in the annex at the end of the document.

Important: currently, our system does not yet allow the issuance of this type of receipts, but the technical department is developing this functionality. It is expected to be available shortly. Customers will be informed in due course and specific help documentation will be provided once enabled.

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

No. From July 29, 2025, all products marketed must be adapted. Only users who already have a previous version can continue using it until their obligation deadline.

12. How should concepts like disbursements, financial surcharges, or withholdings be reflected on the invoice?

The regulations distinguish between fiscally mandatory concepts, which must appear in the invoicing record regulated by Article 10 of the RRSIF, and voluntary or commercial concepts, which can be included in the invoice but are not part of the invoicing record.

Thus, disbursements, financial surcharges, warranty withholdings, or withholdings on account of IRPF or IS are not included in the "total invoice amount" reflected in the tax QR code or in the registration record. However, they can be included in the printed or electronic invoice as part of the financial information directed to the recipient.

In these cases, it is recommended that the invoicing system clearly shows the differentiated amounts. For example:

Total invoice amount: €1,000
(–) IRPF Withholding (15%): €150
Total to pay: €850

This breakdown can be shown on the invoice to the client, but only the total amount (without withholdings or other adjustments) will be part of the official record.

The Tax Agency, in the Veri*factu invoice verification service, has already anticipated this distinction between the total amount subject to registration and other amounts reflected in the invoice. Below is an example extracted from the AEAT's invoice verification viewer:

13. Where can I check my issued invoices?

With the implementation of Veri*factu and the new electronic invoicing requirements, the AEAT offers unified access to review registered invoices. It is a simple process that enhances traceability and regulatory compliance.

Steps for consultation:

After performing the search, the system will display the invoices registered in Veri*factu that have been submitted to the Tax Agency.

The SII (Immediate Supply of VAT Information) is a system of the AEAT that requires certain taxpayers (large companies, VAT groups, registered in REDEME) to electronically submit billing records to the AEAT in almost real-time. This system allows for the electronic management of VAT record books.

It is important to distinguish it from Veri*factu, as the SII does not regulate how an invoice should be issued, but how its accounting data should be sent. In contrast, Veri*factu establishes technical requirements for the issuance, preservation, and integrity of invoices from their origin, including the possibility (or in certain cases, obligation) of submitting them to the AEAT in real-time.

What is a SIF?

A SIF (Invoicing Computer System) is any system that allows the issuance, dispatch, or storage of invoices or simplified invoices by electronic means. The RD 1007/2023 requires these systems to meet a series of technical requirements, including the generation of an unalterable billing record and, where applicable, the option to operate in Veri*factu mode.

Not all accounting or management software is a SIF: it is only considered as such if it generates documents that are formally considered invoices for tax purposes.

What is the RRSIF?

The RRSIF is the acronym used to refer to the Regulation of Requirements for Invoicing Computer Systems, approved by RD 1007/2023. This regulation establishes the technical obligations that SIFs must comply with, such as integrity, preservation, traceability, and generation of the billing record. It also introduces the Veri*factu operating mode.

What is a self-invoice?

The self-invoice is a modality regulated in Article 5 of RD 1619/2012 where the recipient of an operation (for example, a client or principal) issues the invoice on behalf of the supplier or service provider. For it to be valid, there must be a prior agreement between both parties and an acceptance procedure by the supplier. This modality does not alter the tax responsibility of the service provider, who remains obliged to declare the corresponding VAT.

Based on the definition of Invoicing Computer System (SIF) contained in Article 2 of RD 1007/2023, which states:

Invoicing computer systems are those that allow the issuance of invoices or simplified invoices through their use.

This implies that if the system used generates documents that meet the requirements of a formal invoice (according to Article 6 of RD 1619/2012), it is considered a SIF, regardless of whether another subsequent system submits the data to the SII. The obligation to comply with the RRSIF depends on the act of issuance, not on the transmission of the accounting data.

Although there is no official resolution published that expressly addresses this point, the AEAT has communicated in technical seminars and informational documents that submission through another channel (such as an API to an accounting system) does not exempt from complying with the requirements of the system that originates the invoice, if said invoice has fiscal validity. It is, therefore, an interpretative criterion based on the principle of traceability outlined in the RRSIF.

The handling of these questions can be analyzed based on the provisions in the IRPF Law (Law 35/2006) and the Invoicing Regulations (RD 1619/2012):

Therefore, those who only obtain income from real estate capital and do not engage in economic activity are not required to issue an invoice. They can document the payment with a simple receipt, as long as it does not have the appearance or function of an invoice.

This is consistent with established administrative criteria and the principle of economic reality: an invoice cannot be required where there is no obligation to invoice.

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