What is Verifactu?
Verifactu is the common name for Spain's rules on invoicing software systems (SIF) set out in Royal Decree 1007/2023, with the technical details in Order HAC/1177/2024. It requires the integrity, retention, accessibility, legibility, traceability and immutability of invoice records: a good-looking PDF is not enough.
It helps to separate the regulation from VERI*FACTU mode, which sends invoice records to the Spanish Tax Agency (AEAT). There is also a non-VERI*FACTU mode with local technical safeguards. The obligation is to use compliant software where it applies, not to send every invoice in real time. It is not B2B e-invoicing, and it does not replace SII (Spain's immediate VAT reporting system).
When is Verifactu mandatory? Updated calendar
These are the legal dates checked when this guide was updated. Note the difference between deadlines for users, for software producers, and the announced change.
| Group or change | Date | Status and source |
|---|---|---|
| Affected corporate income tax payers | 1 January 2027 | In force: Royal Decree-law 15/2025 |
| Other taxpayers under article 3.1 | 1 July 2027 | In force: RD 1007/2023, consolidated |
| Software producers and resellers | 29 July 2025 | General deadline for adapting products; see maintenance contracts in the regulation |
| Delay of outstanding obligations | October 2028 | Announced, not yet in the legal text consulted: Ministry of Finance note |
What the Ministry announced on 5 October 2026 and what is still missing
The note proposes aligning the outstanding software obligations with e-invoicing for SMEs and the self-employed in October 2028. It also foresees bringing scopes and technical aspects closer together, while keeping substantially equivalent safeguards. It describes a planned amendment, not an approved rule.
Changing the deadlines requires approving and publishing the amendment. The announced margin can help coordinate projects, but it does not justify dropping the system inventory, testing or version control. Before setting a go-live date, check the AEAT portal and the BOE again.
Does Verifactu or SII apply to you? The first decision
The decision is made per taxpayer and activity, not by the name of the ERP. Review tax residence and domicile, invoicing obligations, tax regime and the systems used. The AEAT sets out the scope and exclusions; not every company that issues an invoice in Spain has the same obligation.
Companies in SII: excluded from Verifactu
Taxpayers that keep their VAT books through SII are excluded from the invoicing software regulation, whether they joined SII mandatorily or voluntarily. SII keeps working under its own rules. Do not enable VERI*FACTU for an entity already in SII just because the feature appears in NetSuite.
Companies outside SII: Verifactu or voluntary SII
If you are in scope and outside SII, you will need to adapt your system to the applicable calendar. Joining SII voluntarily may be an alternative, but it changes how you record transactions and file returns. It is not a technical shortcut: compare the recurring obligations and cost of each option with your tax adviser before applying.
Basque Country and Navarre: TicketBAI and foral systems
Taxpayers domiciled in the foral territories follow different rules. In the Basque Country, TicketBAI and, where applicable, Batuz have their own regulations; Navarre has its own foral regime and should not be treated as if TicketBAI applied across the board. If you operate in several territories, analyse the competent tax authority and each obligation with specialist advice.
There are also excluded cases and authorised exceptions. Do not assume that a simplified invoice, third-party invoicing or an Excel process is automatically out of scope: what matters is the real activity and whether the tool acts as invoicing software.
Technical requirements for invoicing software (SIF)
The system must create registration records and, where needed, cancellation records with tax data, software identification, a timestamp and a chained hash. The chain makes tampering detectable: corrections never mean silently deleting an invoice that was already issued.
- Integrity and traceability: identify each record and link it to the previous one as specified.
- Retention and access: retrieve legible information, export it and respond to inspections.
- Signature and events: meet the specific requirements of non-VERI*FACTU mode when chosen.
- QR code: add it according to the software rules; in VERI*FACTU mode, add the required wording.
The AEAT QR code and verification service let the recipient check or submit information depending on the mode. They are not a certification of the PDF, nor confirmation that the invoice has been paid.
VERI*FACTU mode vs non-VERI*FACTU mode
| Aspect | VERI*FACTU | Non-VERI*FACTU |
|---|---|---|
| Records | Continuous submission to the AEAT | Kept in the system, ready to be handed over |
| Record signature | Not required in this mode | Required under the technical rules |
| Operations | Manage submissions, responses and incidents | Manage signatures, archive and event logs |
| Invoice | QR code and VERI*FACTU wording or legal equivalent | QR code under the applicable rules, without that wording |
VERI*FACTU can reduce part of the local technical burden, but it does not remove the duty to keep invoices or resolve rejections. The alternative mode requires stronger internal controls. Neither is better for everyone: evaluate the solution, the support and what happens when the connection fails. The choice cannot be switched freely from one invoice to the next.
How NetSuite complies with Verifactu
The European Union Electronic Invoicing SuiteApp, not Spain Localization
Oracle documents the Spanish flow for outbound invoices and credit memos in European Union Electronic Invoicing. It should not be confused with Spain Localization, which covers tax features and SII. Installing a Spanish localization does not mean VERI*FACTU is enabled. See Oracle's transactions guide and the Spain Localization scope.
How the flow works: e-document, Avalara, URL, QR and statuses
The documented template is Avalara Veri*Factu outbound Invoice/Credit memo. It is linked to a Spanish subsidiary, and the customer is assigned the Verifactu E-Document Package. When the transaction is saved with the template selected, generation and certification begin.
Oracle describes the For Generation and Ready for Certification statuses, the Generate E-Document and Certify E-Document actions, and the E-Document Audit Trail. The service provider handles certification. The transaction gets a VERI*FACTU URL that can be shown as a QR code on the PDF. Do not confuse generation, submission and the certification result: check responses and incidents.
The software's statement of compliance in NetSuite
Oracle provides English and Spanish versions of the statement (declaración responsable) in the File Cabinet: SuiteApps → com.netsuite.euelectronicinvoicing → statement → ES. Find the document for the version you use and keep it with the project documentation. A producer's statement is not prior AEAT approval and does not guarantee that all your customisations are correct.
Verifactu and SII in the same account: the incompatibility that affects groups
Oracle warns that the Spanish features of this SuiteApp and the SII features of Spain Localization are mutually exclusive. The page does not specify clearly enough how granular that limitation is for mixed groups. Do not assume that selecting different subsidiaries is enough to solve it.
If some entities are in SII and others are not, confirm the scope in your account with Oracle and design the solution before installing or changing features. Setting a template per subsidiary does not prove that coexistence is supported.
Alternatives: partner localizations
A partner localization or a specific integration can be evaluated. Ask for scope by document and entity, the statement of compliance, error handling, version compatibility and maintenance terms. A connector does not guarantee compliance on its own: the Oracle route with Avalara is one option to weigh against the requirements of your environment.
How to enable Verifactu in NetSuite, step by step
This sequence is based on Oracle's help pages. Menus may vary by language, role and release. Start with a controlled setup in a sandbox, with finance and IT owners, rather than experimenting on real invoices.
1. Inventory of systems that issue invoices
List NetSuite, point of sale, e-commerce and vertical applications along with the entities and number series they use. Separate the system that issues the tax invoice from those that only receive or record it. Decide who fixes errors and avoid issuing the same invoice twice from e-commerce and the ERP.
2. Prerequisites: OneWorld, tax setup and Spanish subsidiary
Oracle requires OneWorld, Custom Transactions and these SuiteApps: Advanced Localization Features, Electronic Invoicing, EMEA Localization, Localization Assistant and NetSuite Electronic Business. The standard roles listed in the installation prerequisites must also be active.
SuiteTax is not listed as a requirement on the page consulted. Check the tax engine, your release's dependencies and the Spanish subsidiary's taxes with Oracle. Before going further, resolve any SII incompatibility and confirm the licences and services you need.
3. Installation and e-document template per subsidiary
After installing the dependencies and the SuiteApp, go to Setup → E-Documents → E-Document Templates. Edit the Avalara Veri*Factu outbound Invoice/Credit memo template, select the Spanish subsidiary and save. Review the connection and certification terms; the template alone does not complete the go-live.
4. Customers, roles and required fields
On the customer record, E-Document tab, assign the Verifactu E-Document Package. For roles that handle transactions, Oracle requires the Custom Record Entries permission at View level or higher. Grant permissions that match each user's responsibility.
Validate invoice type, transaction classification, regime key and recipient identification. Oracle documents fields that are filled in automatically and where their values come from; check that the result reflects the real transaction. Do not use default values to hide VAT, exemption or foreign-recipient errors.
5. The QR code in custom PDF templates
Go to Customization → Forms → Advanced PDF/HTML Templates. Oracle's guide includes a snippet that generates the QR code from the custbody_euei_es_vf_transaction_url field. Review every custom template, language and print format: a correct standard template does not automatically fix the custom ones.
Check legibility when printed, the link target and the VERI*FACTU wording. If the field is empty, investigate the flow and the service response; never build a fake URL just to make a code appear. Use the example in the official QR documentation.
6. Master data quality
Clean up tax IDs (NIF), legal names, addresses, foreign customer identification, number series and tax rates. Include credit memos, corrective invoices, exemptions and special transactions in the review. Assign a data owner: fixing a record without reviewing pending transactions will not resolve every rejection.
7. Testing in the sandbox and in the AEAT test environment
The NetSuite sandbox and the tax authority's test environment are not the same thing. Confirm that the connection uses the test service and will not send real records. Run issuing, correction, cancellation and communication failures; review statuses, audit trail, provider identifiers and QR codes.
Set the cut-off date, the incident queue and who approves go-live. If you need to review customisations, see our NetSuite implementation and NetSuite optimization services. For the Spanish tax scope, also see our guide to Spanish tax localization in NetSuite and Oracle's localization documentation.
Penalties for not complying with Verifactu
Article 201 bis of the Spanish General Tax Law separates the conduct of the software producer from that of the system's user. Among other cases, it sets fines of €150,000 per financial year and type of system for certain production or sales infringements, and €50,000 per financial year for possession in the circumstances set out in law.
These are not automatic fines for any invoice error: the conduct, the requirements and when they become enforceable all matter. There is also a specific case of selling uncertified software, penalised per system sold. Get tax advice on your situation, and keep evidence of versions, the statement of compliance, tests and incident handling.
Verifactu, B2B e-invoicing and SII: dates and how they fit
These are separate obligations, even if it makes sense to coordinate them in one project. The software rules cover records and systems; B2B e-invoicing covers exchanges between businesses; SII reports VAT books. A QR code does not turn a PDF into a structured e-invoice.
| Obligation | Calendar | Reference |
|---|---|---|
| SIF / Verifactu | 1 January 2027 or 1 July 2027; delay to 2028 announced | RD 1007/2023 |
| B2B e-invoicing: annual turnover above €8 million | 6 October 2027 | AEAT calendar |
| B2B e-invoicing: other affected businesses and professionals | 6 October 2028 | Order HAC/1028/2026 |
| SII | Already in force, with its own reporting deadlines | SII at the AEAT |
The B2B dates do not automatically replace the software calendar. Review turnover, scope and the transitional rules of each regulation. Our guide to the Crea y Crece law (in Spanish) gives more context; to set dates, always use the latest official source.
Common mistakes when preparing NetSuite for Verifactu
- Treating the delay as approved: a Ministry note does not replace an amendment published in the BOE.
- Enabling it for an entity in SII: check the tax scope and Oracle's published incompatibility first.
- Forgetting point of sale and e-commerce: the project must cover every system that actually issues invoices.
- Not adapting custom PDFs: test the QR code, URL and wording in every template in use.
- Keeping parallel invoices unchecked: assess Word, Excel and macros by what they actually do; avoid untraceable paths.
- Confusing submission with acceptance: monitor errors and certification, not just document generation.
- Promising zero cost: separate licences, certification provider, implementation and support.
Frequently asked questions
Can I enable Verifactu voluntarily before it becomes mandatory?
Yes, if your company is within the scope of the regulation and the system has been adapted. Before starting, validate the production environment and the lock-in rule: once you begin submitting records in VERI*FACTU mode, you must keep doing so at least until the end of the calendar year of the first submission. Do not enable this flow for an entity that is excluded because it reports under SII.
What happens to invoices issued before Verifactu is enabled?
Enabling it does not turn historical invoices into records sent to the Spanish Tax Agency (AEAT). Keep the earlier archive as required and set a cut-off date. Test later corrective invoices or cancellations linked to older documents with your provider and tax adviser; do not resend the whole history as if it were new.
Do foreign subsidiaries of a Spanish group have to comply with Verifactu?
Not merely because they belong to a Spanish group. Each entity must be analysed: its residence, its tax obligations and any permanent establishment in Spain. In OneWorld, assigning a subsidiary to a template does not replace that legal analysis or justify enabling the Spanish flow for every subsidiary.
Does Oracle's e-invoicing SuiteApp cost extra?
Oracle documents that Electronic Invoicing can be installed free of charge, with free use for one country and paid licences for some multinational scenarios. That does not prove that European Union Electronic Invoicing, Avalara certification, configuration and support are included in your contract. Ask for a breakdown for your account before budgeting.
For licensing, see the Electronic Invoicing terms published by Oracle. The availability of the base SuiteApp does not establish the final price of a VERI*FACTU solution.
Official sources and update policy
This guide separates regulation in force, announcements and documented product features. It is not tax advice and does not confirm any specific configuration. Capabilities, contracts and dates should be reviewed before enabling or publishing changes.