If you invoice out of Odoo in Spain — or you're planning to before 2027 — VeriFactu isn't a nice-to-have feature sitting on a future roadmap. It's a legal obligation with real financial penalties, and it applies to your billing software (SIF, in the Spanish acronym) whether or not you actually intend to use it to issue invoices. This article covers what VeriFactu actually is, what the regulation requires, when it genuinely kicks in, and what happens if your ERP isn't ready for it.
Key point: VeriFactu doesn't mandate e-invoicing or a new invoice format. It requires that whatever system issues your invoices generate, at the exact moment each invoice is issued — or immediately before, never after —, a billing record chained to the previous one through a cryptographic hash, and keep that record tamper-proof. A system that builds that record later, manually or through an overnight batch job, doesn't comply, even if it ends up storing the same data.
What exactly is VeriFactu?
VeriFactu is the popular name for the technical requirements set out in the Reglamento de Sistemas Informáticos de Facturación (RRSIF), approved by Royal Decree 1007/2023, which develops article 29.2.j) of Spain's General Tax Law. It's a separate obligation from the Crea y Crece B2B e-invoicing mandate — that one has its own timeline and governs invoice format and exchange between businesses. VeriFactu instead regulates how your billing software must behave internally, not how you exchange the document with your customer.
The regulation covers two modes. Under VERI*FACTU mode, your Odoo instance sends every billing record to the AEAT's electronic office in near real time, and the invoice carries a QR code plus the label «VERI*FACTU» — in exchange, the law presumes the system is compliant and eases certain retention duties. Under non-VERI*FACTU mode, the system still generates the same chained, signed record, but keeps it locally instead of auto-submitting it, and must be able to produce it for the AEAT on request.
What does the regulation actually require?
Beyond the name, here's what RD 1007/2023 actually demands from any billing software system:
- A billing record for every invoice issued, chained to the previous one through a cryptographic hash that makes it impossible to alter or delete invoices without leaving a trace.
- The record has to be generated at the same moment the invoice is issued, or immediately before — never afterwards, whether through an overnight batch job or a manual step.
- An electronic signature or timestamp proving exactly when the record was created.
- The option to auto-submit records to the AEAT's electronic office in real time (VERI*FACTU mode), printing a QR code on the invoice.
- Retention, accessibility, readability and tamper-evidence for every record generated, whether or not you're running VERI*FACTU mode.
- The system can't allow records to be hidden, altered or deleted without a trace — which is exactly what article 201 bis of the General Tax Law explicitly penalizes.
Real deadlines: when VeriFactu actually kicks in
The deadlines have shifted more than once. These are the ones currently in force after Royal Decree-Law 15/2025 — the ones you should actually plan around, not earlier drafts:
Summary table: VeriFactu deadlines and penalty
| Who / scenario | Date or amount | Legal basis |
|---|---|---|
| Companies subject to Corporate Income Tax | Mandatory from 1 January 2027 | RD-ley 15/2025 |
| Self-employed and all other taxpayers | Mandatory from 1 July 2027 | RD-ley 15/2025 |
| Invoicing software vendors | Must certify the product (already in force) | RD 1007/2023 |
| Non-certified system in use | Fine of up to 50,000 EUR per tax year | Art. 201 bis LGT |
The real penalty: up to 50,000 EUR per tax year
Article 201 bis of Spain's General Tax Law fines the manufacture, sale, distribution or mere possession of billing software that doesn't meet the regulation's requirements — or that allows keeping parallel accounting records, altering records already saved, or failing to reflect every transaction — with up to 50,000 EUR per tax year. The AEAT doesn't need to catch a specific manipulated invoice to apply it: the infraction is having a non-compliant system installed and in use, regardless of whether it was ever actually misused.
This is the part that catches people off guard: a plain, out-of-the-box Odoo install without the compliance module — one that issues even a single invoice, credit note or corrective invoice — already counts as your billing software system for legal purposes. And as such, it can be exposed to this fine once the 2027 deadlines land, regardless of whether there was ever any intention to defraud anyone.
Is your Odoo already exposed, even if you don't actively invoice from it?
It's common to find companies using Odoo for CRM, inventory or purchasing, while invoicing «for real» from a separate system, assuming Odoo simply doesn't count. The problem is that issuing even a single invoice, credit note or export invoice from Odoo, even just once, is enough to make that Odoo instance a billing software system subject to the regulation too.
By default, Odoo's native invoicing — Community or Enterprise, with no third-party extensions — doesn't generate the hash-chained billing record or handle AEAT submission in VERI*FACTU mode. It needs a certified extension built specifically for that purpose; it isn't something you can configure your way around inside stock Odoo.
How to get VeriFactu-compliant in Odoo
The first step, before spending anything, is knowing exactly where your real setup stands. Our Verifactu Readiness Check is a free, no-strings-attached audit: we review your actual Odoo invoicing configuration and tell you precisely what's missing to comply, with concrete findings instead of a generic checklist.
For the compliance work itself, we built flexigo_spain_verifactu (VeriFactu Spain — AEAT RRSIF Compliance), available for Odoo 17, 18 and 19: it adds the hash-chained billing record, the signature/timestamp, the QR code on the invoice, and real-time submission to the AEAT under VERI*FACTU mode.
If your setup has extra complexity — multi-company, custom invoicing flows, migrating from another ERP — our Odoo 19 implementation service gets everything configured and tested well before the deadline hits, not after.
Useful links within FlexigoTech
Frequently asked questions
What happens if my ERP isn't adapted to VeriFactu, even if I barely invoice from it?
It's still your billing software system for legal purposes, and as such it can be subject to the fine of up to 50,000 EUR per tax year under article 201 bis of the General Tax Law once your applicable deadline arrives (1 January or 1 July 2027). The fine applies to having a non-compliant system installed and in use, not to how often you invoice with it.
What are the exact VeriFactu deadlines in 2027?
Under RD-ley 15/2025: 1 January 2027 for companies subject to Corporate Income Tax, and 1 July 2027 for every other taxpayer, including the self-employed. Invoicing software vendors already have an obligation to certify their products.
Is VeriFactu the same as the Crea y Crece B2B e-invoicing mandate?
No. They're two separate obligations with independent timelines. VeriFactu governs how your software must generate and protect each billing record internally. The Crea y Crece mandate governs invoice format and exchange between businesses. They can overlap in time, but neither replaces the other.
How much exactly is the fine for not complying with VeriFactu?
Up to 50,000 EUR per tax year, under article 201 bis of the General Tax Law, applying both to whoever develops, sells or maintains the non-compliant system and to whoever has it installed and in use. No specific manipulated invoice needs to be detected — merely possessing or using the non-certified system is the sanctionable act.
How do I start checking whether my Odoo complies with VeriFactu?
Start with the Verifactu Readiness Check, our free audit: we review your actual Odoo configuration and tell you, with no strings attached, exactly what's missing. From there, if needed, we install the flexigo_spain_verifactu module or help with the full implementation.
Want to know if your Odoo complies with VeriFactu?
We start with the free audit, and on the first call we'll tell you exactly where you stand and what's missing. Email us at comercial@flexigobe.com or call +34 639 913 105.
