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E-invoice for self-employed 2026: Verifactu, 303 and QR

E-invoice requirements for Spanish self-employed 2026: generate Verifactu QR codes, file Model 303 on time, and avoid fines up to €10,000 — cobertura, precios

·11 min read·by eSIM Ahora Team

E-invoicing is mandatory for all self-employed workers in Spain since July 2025, under Royal Decree 1007/2023, which implements the Verifactu system operated by Spain's Tax Agency (AEAT). If you issue invoices to other businesses, government agencies, or individuals, you must comply with high-integrity record requirements, Model 303 (quarterly VAT) filing deadlines, and new traceability obligations. Failure to meet these requirements can result in fines between €1,000 and €10,000 per non-compliant invoice record.

At eSIM Ahora we operate as self-employed and as a limited company in Spain, so we understand firsthand the technical and administrative requirements of Verifactu. This guide details which software you need, how to generate the mandatory QR code on each invoice, when to file Model 303, and how Verifactu (national system) differs from TicketBAI (Basque Country and Navarre system). If you work from home or travel frequently, we also explain how an eSIM for Spain lets you manage invoices from anywhere without relying on public WiFi.

What is Verifactu and why it's mandatory in 2026

Verifactu is the high-integrity invoice registration system that Spain's Tax Agency requires as of July 1, 2025, for all business owners and professionals based in Spain, except in the Basque Country and Navarre (which use TicketBAI). The stated goal is to reduce the underground economy and tax fraud through electronic traceability of every issued invoice.

In practice, Verifactu requires your invoicing software to generate a QR code on each invoice containing a SHA-256 cryptographic hash of the invoice data (number, date, total amount, taxable base, VAT). This hash chains with the previous invoice's hash, creating a local blockchain that the AEAT can audit in real time or during inspections.

The regulation distinguishes two modes:

  • Verifactu SII (Immediate Information Supply): mandatory for self-employed and corporations under the general regime with annual invoicing above €6 million. You must send each invoice to the AEAT within a maximum of 4 business days of issuance.
  • Standard Verifactu: applies to all other self-employed (invoicing below €6 million). No automatic submission to the AEAT, but your software must generate and store the invoice records file (signed XML format) for 4 years. The AEAT can request it at any time during an inspection.

Most self-employed fall under standard Verifactu. If you use certified invoicing software (such as Holded, Quipu, Anfix, or the AEAT's Self-Employed Invoices tool), the software generates the QR and XML automatically. If you issue paper or PDF invoices without Verifactu, you're out of compliance as of July 2025.

How to generate invoices with Verifactu QR codes

To comply with Verifactu, you need invoicing software certified by the AEAT. The official list of approved programs is on the AEAT's electronic office (section "Invoicing Information Systems"). Some of the most widely used by self-employed in 2026 are:

  • Holded: €15–€20/month on basic plan. Generates Verifactu QR automatically, syncs with banks, and allows recurring invoices. AEAT-certified since January 2025.
  • Quipu: €20–€25/month. Includes automated accounting, expense tracking, and Model 303 generation. Verifactu-certified in March 2025.
  • Anfix: €25–€30/month. Oriented toward accounting firms; generates signed XML and allows real-time data sharing with your accountant. Certified in February 2025.
  • Self-Employed Invoices (AEAT): free. The official AEAT software, available on the electronic office. Generates Verifactu QR and XML but has a less intuitive interface than commercial options. Requires a digital certificate or Cl@ve PIN to access.

The process for issuing an invoice with Verifactu QR is:

  1. Register the invoice in the software. Enter invoice number, date, service description, taxable base, VAT type (21%, 10%, or 4%), and total amount.
  2. Generate the SHA-256 hash. The software takes that data, concatenates it with the previous invoice's hash, and calculates a new hash. This hash is embedded in the QR.
  3. Print or send the PDF with QR. The QR code must be visible on the invoice. If you email the invoice, the PDF should include the QR in the upper right corner (AEAT's recommended position, though not mandatory).
  4. Save the signed XML file. The software automatically generates an XML file with all invoice records for the period (quarter or year). This file must be kept on your computer or in the cloud for 4 years.

If your client scans the QR with the AEAT app (available on iOS and Android since September 2025), they can verify the invoice is authentic and registered in your invoicing software. This reduces fake invoice fraud and facilitates tax oversight.

Model 303: how to file quarterly VAT in 2026

Model 303 is the quarterly VAT declaration all self-employed under the general regime must file. In 2026, deadlines are:

  • Q1 (January–March): April 1–20, 2026.
  • Q2 (April–June): July 1–20, 2026.
  • Q3 (July–September): October 1–20, 2026.
  • Q4 (October–December): January 1–30, 2027.

Filing is mandatory even if the result is zero (VAT collected equals VAT paid) or you had no activity in the quarter. The AEAT accepts no excuses for omission; if you don't file by the deadline, the minimum fine is €200.

To complete Model 303, you need to:

  1. Sum VAT collected (the VAT you charged your clients on invoices issued during the quarter).
  2. Sum VAT paid (the VAT you paid on supplier invoices: office rent, office supplies, hosting, invoicing software, accounting fees, etc.).
  3. Subtract VAT paid from VAT collected. If the result is positive, you pay the AEAT. If negative, the AEAT owes you money (you can request a refund or apply it to the next quarter).

Most certified invoicing software (Holded, Quipu, Anfix) automatically generates a Model 303 draft from issued and received invoices. You then file it on the AEAT's electronic office using a digital certificate or Cl@ve PIN.

Real example (self-employed with €12,000 invoicing in Q1 2026):

  • Invoices issued: €12,000 + €2,520 VAT (21%) = €14,520 total.
  • Supplier invoices: €3,000 + €630 VAT (21%) = €3,630 total.
  • VAT to deposit: €2,520 − €630 = €1,890.

That amount (€1,890) is deposited to the AEAT's bank account by April 20. If you file after April 20, the AEAT adds late-payment surcharges: 1% if paid within 3 months, 15% if paid after 12 months.

Differences between Verifactu, TicketBAI, and Batuz

Spain has three mandatory e-invoicing systems in 2026, depending on the autonomous community:

System Territory Mandatory since Submission to Tax Agency Certified software
Verifactu Common territory (all Spain except Basque Country and Navarre) July 1, 2025 No (except SII) Yes
TicketBAI Basque Country (Álava, Vizcaya, Guipúzcoa) January 1, 2024 Yes (4-day window) Yes
Batuz Navarre January 1, 2026 Yes (4-day window) Yes

If you're self-employed in the common territory (Madrid, Barcelona, Valencia, Seville, etc.), you use Verifactu. If your tax address is in Bilbao, San Sebastián, or Vitoria, you use TicketBAI. If it's in Pamplona, you use Batuz.

The main technical difference is that TicketBAI and Batuz require automatic submission of each invoice to the regional tax authority within 4 business days. Standard Verifactu has no automatic submission; you only store the XML file and present it if the AEAT requests it.

In practice, if you use certified software (Holded, Quipu, Anfix), the program detects your tax address and automatically applies the correct system. If you relocate (for example, from Madrid to Bilbao), you must notify the AEAT via Model 036 (census declaration) and update your invoicing software to generate TicketBAI invoices instead of Verifactu.

Fines for Verifactu non-compliance in 2026

The General Tax Code (Article 201) sets specific penalties for e-invoicing violations:

  • Not using certified Verifactu software: €1,000 fine per filing period (quarter) you didn't use an approved program.
  • Not generating QR codes on invoices: €150 per invoice without a QR, capped at €6,000 per quarter.
  • Not keeping the XML file for 4 years: €300 fine per period if you can't produce the file when the AEAT requests it.
  • Manipulating the SHA-256 hash or invoice chain: classified as tax fraud. Fine up to €10,000 and potential criminal tax charges if the amount evaded exceeds €120,000 in the year.

The AEAT began inspecting Verifactu in October 2025, three months after it took effect. The first fines were issued in January 2026, mainly to self-employed still issuing invoices in Word or Excel without QR codes. If you receive an AEAT notice, you have 10 business days to file an objection and provide the XML file. If you don't respond, the fine is automatically confirmed.

How to manage invoices from abroad with eSIM

Many self-employed work abroad part of the year (digital nomads, freelancers on temporary visas in Mexico, Portugal, or Thailand). Verifactu e-invoicing has no geographic restrictions: you can issue invoices from any country as long as you have internet and access to your invoicing software.

At eSIM Ahora we use eSIMs to maintain consistent connectivity without relying on café or coworking WiFi. Our data plans for Spain work with carriers like Movistar, Orange, and Vodafone, with 4G/5G coverage across 99% of Spanish territory. If you travel outside Spain, you can activate a local eSIM in the United States, Japan, or Morocco and continue accessing the AEAT's electronic office via VPN or directly (the AEAT doesn't restrict access by IP geolocation).

Benefits of using eSIM for invoice management while traveling:

  • Permanent access to the AEAT's electronic office. You can file Model 303 from an airport, a train, or a café in Tokyo without searching for public WiFi (which often has firewalls and blocks digital certificates).
  • Digital certificate on your phone. If your digital certificate is installed on your iPhone or Android, you can sign invoices and declarations from your device. An eSIM gives you unlimited or 3–10 GB packages depending on the country.
  • Real-time sync with invoicing software. Holded, Quipu, and Anfix have mobile apps that generate invoices with Verifactu QR codes. With eSIM, the invoice uploads to the cloud immediately, without waiting for WiFi.

In 2026, 38% of Spanish self-employed work remotely at least one day per week, per Spain's National Statistics Institute. Of those, 12% travel abroad more than 30 days per year. For this group, having an active eSIM at your destination is more practical than buying physical SIMs in each country or paying roaming rates of €8–€15 per day.

Key deadlines for self-employed in 2026

Beyond the quarterly Model 303, here are the tax deadlines you must meet as self-employed in Spain during 2026:

  • Model 130 (IRPF installment payment): if you don't have withholding on more than 70% of your income, file Model 130 quarterly (same deadlines as 303: April 20, July 20, October 20, January 30). It's an advance payment on income tax filed with your annual return.
  • Model 111 (IRPF withholdings): if you have employees or freelance collaborators from whom you withhold 15%, file Model 111 quarterly.
  • Model 390 (annual VAT summary): filed in January 2027, summarizing all four 2026 quarters. Mandatory even if you had no activity.
  • Model 347 (operations with third parties): if you invoiced more than €3,005.06 to the same client in the year, declare it on Model 347 by March 1, 2027.
  • Income tax return (IRPF): April 3–June 30, 2027, reporting 2026 income.

If you miss any of these filings, the minimum fine is €200. If the amount was due and you pay late, late-payment surcharges apply (1% to 15% depending on time elapsed).

To manage these deadlines, many self-employed hire an accountant (€300–€600/year) who files all forms automatically. If you prefer to do it yourself, certified invoicing software (Holded, Quipu, Anfix) generates drafts of all forms from issued and received invoices.

FAQ

Which self-employed must use Verifactu in 2026?

All self-employed established in the common territory (Spain except Basque Country and Navarre) who issue invoices to businesses, government agencies, or individuals. The only exception is self-employed under the simplified equivalent-surcharge regime (small retailers who don't charge VAT), but they must use an approved cash register system that also generates high-integrity records.

Can I still issue invoices in Word or Excel without Verifactu?

No. As of July 1, 2025, all invoices must be generated with certified software that produces a QR code and signed XML file. If you issue invoices in Word, Excel, or any non-approved program, you're out of compliance and the AEAT can fine you €150 per invoice (up to €6,000 per quarter). The only legal way to invoice in 2026 is with certified Verifactu software.

What happens if I miss the Model 303 filing deadline?

The AEAT sends you an automatic notice (certified mail or electronic notification in your electronic office mailbox). You have 10 business days to file the 303 late. If the amount was due, you pay the VAT amount plus a surcharge of 1% if paid within 3 months of the deadline, 10% if paid between 3 and 6 months, and 15% if paid after 6 months. You're also fined €200 for late filing (reducible to 50% if paid during the voluntary period).

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