(And why “I invoice with Excel” does not mean you’re exempt)

If you’ve been reading about VeriFactu, you’ve probably seen this line everywhere:

“VeriFactu only applies if you use invoicing software.”

That little clause is causing a ton of confusion — especially among freelancers and small online sellers. Some people hear it and think:

• “I don’t use invoicing software, I just use Excel, so I’m fine.”

• “My plumber writes receipts by hand, so what happens with those invoices?”

• “Do I need to upload manual invoices somewhere on the tax office website?”

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

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1. What VeriFactu regulates (in one sentence)

VeriFactu does not change Spain’s invoicing rules.

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

So the key trigger is:

• Are you issuing invoices through a billing system/software (“SIF”)?

If yes → you’re in scope.

If no → you may be outside scope.

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2. The only people truly outside VeriFactu

You are outside VeriFactu only in these cases:

• You issue invoices 100% manually (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 (Immediate Supply of Information).

SII taxpayers are excluded because they already report invoices through another system.

• You operate under TicketBAI (Basque Country / 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 doesn’t apply to those operations.

That’s it. There isn’t a meaningful “small business” exemption, or an “autónomo exemption”.

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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,

• 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 don’t use invoicing software. I just use Excel.”

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

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3B. Binding ruling V2653-24: Excel and VeriFactu (official clarification)

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 Dirección 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 (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, they have two routes:

• Option 1: Use a 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.

The Tax Agency will offer a free tool to issue invoices under VeriFactu, expected to be available from September 2025, with some limitations compared to full commercial apps.

Key dates to comply with VeriFactu

• 1 January 2026 → Mandatory for companies (corporate taxpayers).

• 1 July 2026 → Mandatory for self-employed and all remaining taxpayers.

Using non-adapted software after these deadlines can trigger penalties of up to €50,000 per tax year.

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

Let’s 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/IRPF in the normal way.

Scenario B: “manual-looking”, but digital (with an important nuance)

A plumber uses Word or Excel only as a “typewriter”:

• fills a template manually,

• prints/PDFs it,

• doesn’t use the file to generate VAT books, accounting, or automated tax outputs,

• and doesn’t 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.