Verifactu and e-invoicing, a double filing to the tax agency: tax advisers warn of discrepancy letters and extra costs for the self-employed
Aedaf alerts to the overlap between Verifactu and mandatory e-invoicing: two filings per transaction, risk of tax queries and extra software costs.
The self-employed lawyer who has already adapted billing software to Verifactu may be in for a surprise: mandatory business-to-business e-invoicing coexists with that system by sending the same information through another channel, and if the data do not match, the tax agency will knock on the door. That is the warning from Fernando Matesanz, member of the European Commission's VAT Expert Group and coordinator of the VAT group of the Spanish Association of Tax Advisers (Aedaf), in statements to Autónomos y Emprendedores.
Two channels for the same invoice
The overlap is simple to explain and costly to bear. If a small business provides a service to a Spanish company and issues the invoice through a Verifactu-mode programme, that software automatically sends the tax agency a record with the transaction data. At the same time, e-invoicing rules require sending the agency an electronic copy of the same invoice, with the same data that appear in the billing records.
Matesanz puts the core objection on behalf of Aedaf: what sense is there in adding a system like Verifactu, as currently designed, if e-invoicing already requires a faithful copy to be delivered to the tax agency? The advisers' proposal is that information be transmitted once and that the agency itself use it for whatever control purposes it considers necessary.
The real risk: a badly reported correction
The practical problem lies less in issuance, which software can automate, than in corrections. When an issued invoice is amended and the change is not properly reflected across all channels, the tax agency receives different data about a single transaction. That discrepancy can turn into incidents, requests or checks that the taxpayer will have to explain, even if the software sent everything without manual intervention.
The answer, the expert insists, is not simply to automate several filings but to avoid duplicated filings altogether. Until that fix arrives, the self-employed will bear the development, update and maintenance costs providers must assume to meet differing format, procedure and deadline requirements.
Official calendar and announced convergence
The Treasury announced on 5 October its intention to move the pending obligations of the billing-systems regulation to October 2028, aligning them with e-invoicing for the self-employed and small firms, together with later changes to scope and technical aspects. That revision requires amending Royal Decree 1007/2023, and Matesanz recalls that for now there is an official communication, but the implementing measure has yet to be approved and published.
The dates professionals work with today are those of business e-invoicing: 6 October 2027 for those exceeding eight million euros in annual turnover, 6 October 2028 for the rest, and 6 October 2029 for reporting invoice status and payments in the case of individuals and entities under income attribution.
What to ask before paying for software
The practical advice for the solo practice is concrete: when choosing a provider, separate Verifactu compliance from the functions needed to issue and receive e-invoices under the other regulation, and ask about required formats, connection to exchange platforms, delivery of copies to the tax agency and payment reporting. A tool advertised as Verifactu-ready may need new features or additional services at extra cost. For those issuing few invoices, Matesanz recalls an alternative: the tax agency will offer a free public e-invoicing solution.
One more administrative burden on top of the 2026 self-employed quota and its regularisation, the quota freeze of RDL 31/2026 and the management of deductible allowances and mileage the collective already handles.
Source: Autónomos y Emprendedores (29 October 2026).
Related links
Fuentes
- autonomosyemprendedor.es. Accessed 1 November 2026.
The specific data in this article come from the official sources cited.
