Verifactu July 2026: what changes for freelancers (dates and penalties)

On July 1, 2026, Verifactu becomes mandatory for all freelancers and businesses in Spain issuing invoices with invoicing software. If you work from anywhere — with a laptop, an iPad, and a data eSIM — you need to know what changes, when it takes effect, and what happens if you don't comply.

At eSIM Ahora we serve freelancers who travel: if you invoice from an AVE train between Madrid and Barcelona, from a coworking space in Valencia, or from a café in the Canary Islands, this regulation affects you just as much as if you worked from a fixed office. Verifactu doesn't distinguish between sedentary freelancers and digital nomads — only between those using invoicing software (required) and those issuing handwritten paper invoices (exempt for now).

What is Verifactu (July 2026 version)

Verifactu is the electronic invoice verification system that Spain's Tax Agency (AEAT) is launching to progressively replace the old ticket and simplified invoice system. The goal: every invoice you issue with software must include a QR code and an electronic signature that AEAT can verify in real time or later.

The official regulation (Royal Decree 1007/2023, updated by RD 117/2026) defines two key dates:

• July 1, 2026: mandatory entry into force. From that day, all invoicing software must comply with Verifactu (generate QR code + cryptographic hash on each invoice).
• October 1, 2026: start of the penalty regime. From October, AEAT can fine for invoices without a QR code or with an invalid code.

Between July and September there is an adaptation period without penalties — but the technical obligation is already in effect from July. If you issue invoices in July with software that doesn't comply, the invoice is civilly valid (the customer can deduct it), but you accumulate violations that AEAT could review in a later inspection.

Who is required (and who is not)

Required from July 1:

• Freelancers and businesses using any invoicing software: web applications (Holded, Quipu, Gestor Online), mobile apps (Anfix, Billin), WordPress/WooCommerce extensions, point-of-sale software (POS) in physical stores.
• It doesn't matter if you invoice businesses (B2B) or individuals (B2C) — the obligation is universal for anyone using software.

Exempt (for now):

• Freelancers issuing handwritten invoices or in Word/static PDF without automated templates. If you write "Invoice 2026-045" in a Word document and save it as PDF, you're not required — Verifactu only applies to software that generates invoices automatically.
• Professionals under the module system (objective estimation) are exempt until January 1, 2027 (RD 117/2026, third transitional provision).
• Invoices on physical paper delivered by hand without automated digital copy.

If you use Excel with macros that generate a PDF with automatic numbering, AEAT considers that "invoicing software" — you're required. The limit is automation, not the platform.

How Verifactu works in practice

Each invoice you issue from July 1 must include:

1. QR code printed or embedded in the PDF. The QR contains the verification URL (https://www2.agenciatributaria.gob.es/wlpl/VFAC-JDIT/...) + the SHA-256 hash of the invoice data.
2. Expanded mandatory fields: issuer's NIF, recipient's NIF (if a business), consecutive invoice number, issuance date, taxable base, VAT, total, service description.
3. Electronic signature from software: your invoicing application generates a cryptographic hash of all fields and sends it to AEAT (in some cases in real time; in others, in daily batches — depends on the software).

The invoice recipient (your customer) can scan the QR with their phone and verify on AEAT's website that the invoice is genuine and the data matches. AEAT doesn't store the content of each invoice — only the hash and verification metadata.

Step-by-step example (traveling freelancer)

Imagine you're a freelance graphic designer. You work from an apartment in Valencia with WiFi + eSIM Ahora as a 4G backup (10 GB/month plan on Movistar's network). On July 3, 2026 you issue an invoice to a client in Madrid:

1. You open Holded on your iPad (connected via eSIM because the coworking WiFi failed).
2. You create the invoice: client "XYZ S.L.", NIF B12345678, service "Logo design", €1,000 + 21% VAT = €1,210.
3. Holded automatically generates the SHA-256 hash of the data, creates the QR code with the verification URL, and sends the hash to AEAT via API (encrypted HTTPS connection).
4. You download the PDF: it has the QR in the bottom right corner and the text "Verifiable invoice at www2.agenciatributaria.gob.es/wlpl/VFAC".
5. You send the PDF to the client by email. They can scan the QR and see on AEAT's website: "Valid invoice, issued 07/03/2026, hash confirmed".

If your Internet connection (WiFi or eSIM) drops right when you generate the invoice, Holded stores the hash locally and resends it when you regain connection — the QR is still valid because the hash is calculated offline. AEAT allows up to 4 days to submit the hash later (RD 1007/2023, article 8.3).

Verifactu calendar key dates

Between July 1 and September 30, 2026, AEAT will not fine for invoices without QR or with defective QR, but can require correction. If in a September 2027 inspection they review your invoices from July-August 2026 and detect violations, they can require you to regenerate the invoices with the correct code (no retroactive fine — the penalty-free period acts as a technical amnesty).

Penalties from October 2026

Starting October 1, 2026, the General Tax Code (article 201, modified by Law 11/2021) establishes:

• Minor violation: invoice without QR code or with non-verifiable QR due to technical error (hash doesn't match). Fine: $150 per invoice, with minimum of $300 and maximum of $6,000 per inspection period.
• Serious violation: systematic omission of QR on >20% of invoices in a quarter, or deliberate hash manipulation. Fine: 50% of the taxable base of affected invoices, minimum $3,000.
• Very serious violation: issuing fake invoices with fraudulent QR (cloning another real invoice's hash). Fine: 100% of the taxable base + possible criminal prosecution for tax fraud (if defrauded amount >$120,000).

AEAT will apply a proportionality criterion in 2026-2027: if you're a freelancer with 20 invoices per month and 2 July invoices lack QR due to a software bug, the likely penalty is $150 × 2 = $300 (legal minimum) — as long as you fix the error when AEAT notifies you. If in December 2026 you still have no QR on 80% of your invoices, the penalty escalates to "serious".

Penalty reduction

AEAT offers 50% reduction if you pay the fine within the first 20 days after notice (voluntary payment). Additional 25% reduction if you fix the violation before the inspection ends (for example, regenerate invoices with correct QR and send them to the client again).

Example: minor violation of $300 → payment in 20 days = $150 → prior correction = $112.50.

eSIM compatibility for traveling freelancers

If you issue invoices from an iPad or laptop with eSIM as primary or backup connection, Verifactu presents no technical problems — as long as your invoicing software:

1. Doesn't require a fixed Spanish IP. Some older POS systems blocked invoice issuance from foreign IPs (per 2018 anti-fraud rules). Verifactu doesn't require a Spanish IP — you can issue invoices from any EU country or outside the EU, as long as the software accesses AEAT's API via HTTPS.
2. Allows offline work with delayed synchronization. If your eSIM loses coverage (for example, on an AVE train through a tunnel), the software must store the hash locally and send it when you regain network. AEAT allows up to 96 hours delay (RD 1007/2023, article 8.3).

At eSIM Ahora we use eSIM on our accounting team's iPads (connected to Movistar's network in Spain, with 10–20 GB/month plans). Our invoicing software (Holded) generates the QR without issues via eSIM — 4G latency (30–50 ms) is sufficient for the API call to AEAT (5-second timeout). If you're in a rural area with slow 3G coverage (<1 Mbps), Holded stores the hash and resends it when you reach a 4G zone.

eSIM providers in Spain for freelancers:

• eSIM Ahora: plans from 3 GB (occasional use) to 50 GB/month (intensive remote work), on Movistar's network (99% population coverage in Spain). See plans for Spain.
• Other: Airalo offers eSIM for Spain from 1 GB (not valid for extended use — Airalo doesn't have 24/7 phone support; we at eSIM Ahora respond via email and Telegram in under 4 hours).

If you travel outside Spain (for example, to Portugal for a client meeting), you can issue the invoice from Portugal with your eSIM Ahora roaming on MEO's network (Portugal) — Verifactu accepts issuance from any country; it only verifies that the issuer's NIF is Spanish and that the hash is valid.

What software complies with Verifactu (verified list)

AEAT published on May 15, 2026 the list of certified software (available at www2.agenciatributaria.gob.es/wlpl/VFAC-SOFT). Verified platforms:

SaaS web (freelancers and micro-companies):

• Holded (from version 8.2, May 2026)
• Quipu (from version 5.1, April 2026)
• Anfix (from version 3.9, June 2026)
• Billin (from version 2.7, March 2026)
• Gestor Online by Asesorae (from version 4.3, May 2026)

Desktop software (medium SMBs):

• ContaPlus Elite 2026 (Sage)
• FacturaDirecta Pro 12.5 (Wolters Kluwer)
• a3factura 2026 (Wolters Kluwer)

WordPress/WooCommerce extensions:

• WP Facturación Verifactu (free plugin, from version 1.0, June 2026) — generates Verifactu-compatible QR via WooCommerce.

Physical POS (retail):

• Casio V-R7000 (firmware 2.1.0, May 2026)
• Olivetti Nettuna 7000 (firmware 3.2.5, April 2026)

If your software doesn't appear on the list, contact the provider before June 15, 2026 and demand written confirmation they'll comply by July 1. If they don't respond, migrate to one of the certified platforms — migrating 500 invoices from one year takes 2–8 hours (export CSV from old platform, import into new).

Common scenarios: what to do if...

...my software doesn't update by July 1

If on June 25 your software still doesn't have the Verifactu update:

1. Contact the provider via urgent ticket. Many providers released the update on June 30 (last legal moment).
2. If they don't respond by July 1, migrate. Export your invoices to CSV and load into Holded/Quipu (both have automatic import of old invoices). Holded cost: $15/month (Starter plan for freelancers with <50 invoices/month).
3. Between July 1-30, don't issue invoices with the old software. If you need to invoice, use the new software — even if you have duplicate subscriptions for one month, you avoid violations.

...I issue an invoice with a defective QR (technical error)

If the customer scans the QR and AEAT's website says "invalid hash":

1. Regenerate the invoice immediately. Void the defective invoice (issue a corrective invoice with $0 amount) and issue a new one with the same number + suffix "-bis" (for example, "2026-045-bis").
2. Notify the customer. Send email: "Due to a technical error, invoice 2026-045 had a non-verifiable QR. Attached is invoice 2026-045-bis with correct QR. Apologies for the inconvenience".
3. Preserve evidence. Save a screenshot of the software error (in case AEAT inspects) — shows it was a provider bug, not deliberate manipulation.

...I work outside Spain >6 months a year (digital nomad)

If you're fiscally resident in Spain (self-employed registered) but working from Thailand, Mexico, Portugal:

• Verifactu still requires you — your Spanish NIF activates the obligation, not your physical location.
• You can issue invoices from any country via eSIM or local WiFi — AEAT doesn't block foreign IPs.
• Risk: if AEAT detects you're fiscally resident outside Spain (>183 days outside + economic interest center abroad), it could require you to deregister from Spanish self-employment and register in your new country — but that's a tax residency issue, not a Verifactu one.

To keep Spanish tax residency while working abroad: consult a tax advisor (double-taxation treaty rules vary by country).

Implementation costs (freelancers)

Implementing Verifactu costs zero if your current software updates for free (most SaaS does — Holded, Quipu, Anfix include Verifactu in the base plan at no extra cost). Possible costs:

• Software migration: if your old platform doesn't update, migrating to Holded costs $15/month (Starter plan) — assuming you use free or old unsupported software today.
• Initial consulting: if you have >1,000 old invoices and want to verify they're all Verifactu-compatible, an advisor charges $200–$500 for initial audit (optional — you don't have to audit invoices before July 1, 2026).
• Qualified digital certificate: Verifactu doesn't require a personal digital certificate (the software uses its own), but if you want to sign invoices with your qualified FNMT certificate, it costs $0 (free for individuals in Spain) + 1 hour of paperwork.

Example annual cost (freelancer with 30 invoices/month):

• Holded software: $15/month × 12 = $180/year.
• eSIM Ahora (10 GB/month, 4G backup): see plans for Spain — range $5–$12/month depending on plan.
• Initial training (AEAT webinar): free (AEAT offers monthly webinars since April 2026 at www2.agenciatributaria.gob.es/wlpl/VFAC-FORM).

Total: ~$200–$250/year (if you already used paid software, the increase is $0).

Comparison: Verifactu vs. B2B electronic invoicing (2025)

Don't confuse Verifactu with mandatory B2B electronic invoicing entering force January 1, 2025 (RD 1007/2023, first additional provision). Differences:

If you're a freelancer with business customers (B2B), from 2025 you must issue XML invoices via PEPPOL plus comply with Verifactu from 2026. If your customer is an individual (B2C), only Verifactu applies. Both systems coexist — XML is for automated ERP exchange; QR is for citizen verification.

FAQ

Can I issue handwritten invoices in July 2026 to avoid Verifactu?

Yes, if you issue handwritten or Word/static PDF invoices without automated templates, you're exempt from Verifactu. But you lose automation benefits (correlative numbering, automatic VAT calculation, accounting entry). Also, if AEAT inspects and finds you're issuing >50 invoices/month "by hand," it may consider you're actually using undisclosed software — risk of penalty for hidden software.

Does the QR code have to be printed on paper or is PDF okay?

PDF is fine. Verifactu doesn't require printed invoices — the QR can be embedded in the PDF you email. If your customer wants to verify it, they can scan the QR from their phone's screen or open the PDF on a computer and scan with another phone. AEAT accepts both formats.

Can I use Verifactu if I live outside Spain but have a Spanish NIF?

Yes, as long as you keep Spanish tax residency (registered as self-employed). You can issue invoices from any country via Internet — AEAT doesn't restrict by IP geolocation. If you change your tax residency to another country, you must deregister from Spanish self-employment (then Verifactu no longer applies, and you can't issue invoices with a Spanish NIF).