Who Is Actually Outside VeriFactu?

And why "I invoice with Excel" does not mean you are exempt.

If you have been reading about VeriFactu, you have probably seen this line everywhere: "VeriFactu only applies if you use invoicing software."

That little clause is causing a lot of confusion, especially among freelancers and small online sellers.

Some people hear it and think: "I do not use invoicing software, I just use Excel, so I am fine." Others ask what happens with handwritten receipts, or whether manual invoices need to be uploaded one by one to the tax office website.

Let us clarify who is truly outside VeriFactu, who only thinks they are, and what digital businesses in Spain should do next.

1. What VeriFactu regulates in one sentence

VeriFactu does not change Spain's invoicing rules.

It regulates the billing systems, or software, used to issue invoices, requiring them to create traceable, tamper-proof invoice records.

So the key trigger is simple: are you issuing invoices through a billing system or software?

If yes, you are in scope. If no, you may be outside scope.

2. The only people truly outside VeriFactu

You are outside VeriFactu only in these cases:

• You issue invoices 100% manually, with no software at all. For example, paper receipt books, handwritten invoices, or pre-printed forms filled in by hand. If no digital tool generates, numbers, or stores the invoice, VeriFactu does not apply.
• You are in SII, the Immediate Supply of Information system. SII taxpayers are excluded because they already report invoices through another system.
• You operate under TicketBAI in the Basque Country or Navarra. Those territories follow TicketBAI instead of VeriFactu.
• You have a specific legal exemption from invoicing. If your activity is legally exempt from issuing invoices, VeriFactu does not apply to those operations.

That is it. There is not a meaningful small business exemption, or an autonomo exemption.

3. The big misunderstanding: Excel is software

Many freelancers believe VeriFactu only targets proper tools like Quipu or Holded.

But the scope is wider.

If you generate invoices using Excel, Google Sheets, Numbers, Word, Google Docs, PDF templates produced on your computer, or any system that creates, numbers, stores or processes invoices digitally, then you are using a billing system in the sense of the regulation, and VeriFactu applies.

So this idea is wrong: "I do not use invoicing software. I just use Excel."

Legally, Excel is still a digital invoicing tool. If it is used to issue invoices, it must be replaced or integrated with something VeriFactu-ready.

3B. Binding ruling V2653-24: Excel and VeriFactu

This question was addressed directly by the Spanish tax authority in binding consultation V2653-24.

The case involved a professional who issues only a few invoices per month and prepares them in a spreadsheet. The Direccion General de Tributos clarifies two important points.

• If invoices are created entirely by hand, with no software involved in their generation, numbering, or storage, then VeriFactu does not apply.
• If spreadsheets or text processors are used to generate, store, or process invoices, for example using formulas, totals, macros, lists, or any structured invoice archive, they may be considered a billing system, or SIF.

That means they must comply with VeriFactu technical requirements.

So Excel is not automatically allowed or banned. What matters is how Excel is used.

If it behaves like an invoicing system, VeriFactu applies.

If someone stops using Excel

If someone stops using Excel, they have two practical routes:

• Option 1: use VeriFactu-compliant invoicing software. The provider issues a formal declaration that their system meets the VeriFactu rules. It can be cloud-based or installed locally.
• Option 2: use the free AEAT application, when available and suitable for the business. This may be useful for very simple cases, but it will normally have limitations compared with full commercial apps.

Key dates to comply with VeriFactu

Using non-adapted software after the relevant deadline can trigger penalties of up to EUR50,000 per tax year.

• 1 January 2027: mandatory for companies and corporate taxpayers.
• 1 July 2027: mandatory for self-employed taxpayers and most remaining taxpayers.

4. The plumber example: handwritten invoice vs manual-looking digital invoice

Let us take a classic real-life case.

Scenario A: handwritten invoice

A plumber finishes a job and writes a receipt in a paper invoice book, by hand.

• They are outside VeriFactu.
• They do not have to upload that invoice one by one to Hacienda.
• They still must keep copies, record income, and file VAT and IRPF in the normal way.

Scenario B: manual-looking, but digital

A plumber uses Word or Excel only as a typewriter: fills a template manually, prints or PDFs it, does not use the file to generate VAT books, accounting, or automated tax outputs, and does not run macros or keep structured invoice management there.

This computer-as-a-typewriter scenario is basically designed for very traditional, offline trades that issue a handful of invoices and do not manage their invoicing digitally. It is not the standard reality for online businesses.

If you invoice with any digital tool, including Excel, Word, online platforms, TPVs, or billing apps, VeriFactu applies and your system must be ready.

At LIMIT, we provide access to Quipu, a VeriFactu-ready accounting and invoicing software, included with our accounting and tax service, so you can stay compliant with minimal hassle.