Verifactu: the technical order is published

On 28 October 2024 the Official State Gazette published Order HAC/1177/2024 of 17 October, which develops the technical, functional and content specifications of the regulation setting the requirements for the invoicing software of businesses and professionals (Royal Decree 1007/2023). It enters into force the next day. It is the missing piece for software makers to know exactly what they must build.

The obligation comes from the General Tax Act, which requires accounting and invoicing software to guarantee the integrity, preservation, accessibility, legibility, traceability and inalterability of records, to prevent programs that allow data to be manipulated or hidden from the authorities. The order, with 21 articles, two additional provisions and an annex, brings those requirements down to a technical level. The stated aim is not to collect more for its own sake, but for every invoice to be recorded in a way that cannot be altered without leaving a trace.

What the order regulates

It details how invoicing records for issuance and cancellation must be generated, with their format and coding, and how the hash and electronic signature of each record must be calculated. It also sets the content of the event log, traceability and retention requirements, and the minimum content of the declaration of responsibility that whoever produces the software must issue. All this is spelled out in an annex with the structure of the files and the format of each field.

It also regulates the voluntary VERI*FACTU system, in which the software sends records to the Tax Agency as invoices are issued, and the conditions for joining and withdrawing. Any invoice issued with these programs must include a QR code, or the element that replaces it if the invoice is electronic, and, where applicable, the mention that the system is VERI*FACTU. The order also sets how the system must respond to a request from the authorities, sending the records requested in the prescribed format.

Deadlines and who is affected

The 2023 regulation provides that those obliged must have adapted systems operating before 1 July 2025. Producers and sellers of software must offer their products fully adapted within a maximum of nine months from the entry into force of this order, and the Tax Agency must have available within that period the service to receive the records sent by verifiable systems.

With the exceptions the regulation itself provides, it affects businesses and professionals who invoice using software, from self-employed people with an invoicing app to large companies with integrated management systems. The order also provides that the Agency may complete technical details on its website where necessary, so it will be important to consult it. It also regulates the conditions of the invoicing application that the tax administration itself develops, an option intended for those who prefer not to buy a commercial program.

What to review

The first step is to identify which software your company uses to invoice and ask your provider how and when it will adapt it, and whether it will have the declaration of responsibility the order requires. Companies that develop their own software or have bespoke systems must also review the design of their records, traceability and backups.

It is also useful to decide in good time whether the voluntary system, which hands the Agency the continuous sending of records, or the mode without sending suits you better, and to check that invoice templates will allow the QR code to be added. With timetable and requirements now known, leaving the adaptation to the last quarter can prove costly; your adviser can help you plan it. Do not wait until the date approaches: providers may become overloaded and tests with real data take time.

The invoice stays the same; the program that generates it can no longer be opaque.

This article is general information. It is not legal, tax or investment advice, and it does not take anyone’s particular circumstances into account.