Using non-compliant invoicing software after your deadline triggers a fixed 50,000 EUR fine per fiscal year, no matter your revenue. Companies must comply by 1 January 2027. Autonomos and other taxpayers have until 1 July 2027. These dates moved one year later under Real Decreto-ley 15/2025, published in the BOE on 3 December 2025, and most English-language guides still cite the old 2026 dates.
This guide gives you the exact fines, who pays them, when enforcement starts, and the practical steps an autonomo or SL takes to stay clear. For the wider context on the regime itself, see our complete guide to Verifactu.
Real Decreto-ley 15/2025 reset the calendar. The new mandatory dates are:
Voluntary use is open right now. If you opt in early, the same penalty regime applies from the moment you start using a Verifactu system. Companies already in the SII regime are exempt: they keep submitting invoice data through SII and do not need a separate Verifactu setup. For the legal trail behind these fines, check our breakdown of the anti-fraud law that introduced them. It walks through Ley 11/2021 and Article 201 bis LGT.
From your applicable date, every invoice you issue must come from a Sistema Informatico de Facturacion (SIF) that meets the technical requirements of Real Decreto 1007/2023 and Orden HAC/1177/2024. That means a manufacturer's declaracion responsable, an unbroken hash chain, the required QR code on each invoice, and, if you choose Verifactu mode, automatic transmission of records to AEAT.
Article 201 bis LGT is the core of the user-side penalty regime. If you hold or use invoicing software that does not meet the SIF technical standards, the fixed fine is 50,000 EUR per fiscal year. Not per invoice. Not scaled to your revenue. A flat 50,000 EUR.
Software is non-compliant if it lacks the manufacturer's declaracion responsable, if it allows record manipulation, if it cannot generate the required hash and QR, or if it permits double-use accounting. This is the so-called software de doble uso category, the kind of system with a hidden ledger that lets a business under-report sales. It is now expressly outlawed.
The legislator made the fine fixed on purpose. A small autonomo billing 30,000 EUR a year and an SL billing 4 million EUR are both exposed to the same 50,000 EUR. For a low-revenue autonomo this is existential. For an SL it is painful but survivable. Either way, ignoring the rule is not a calculated risk worth taking.
The 50,000 EUR is "per ejercicio". An autonomo who keeps using non-compliant software through 2027, 2028, and 2029 is exposed to 150,000 EUR in cumulative fines. AEAT does not need to catch you in year one. Audits often surface in year three.
Manufacturers, producers, and distributors of invoicing software face a separate, larger penalty: 150,000 EUR per fiscal year, per product type. A vendor selling three non-compliant products is exposed to 450,000 EUR in a single year.
The "per product type" wording matters. A single software house that ships a desktop billing app, a cloud invoicing module, and a POS plugin can be sanctioned three times for the same year. This is why every serious Spanish ERP and invoicing brand is racing to publish a declaracion responsable.
This catches people out. Vendor liability and user liability are independent. If your software is non-compliant, the 50,000 EUR fine lands on you, not on the vendor. You can sue the vendor for civil damages, but that is a separate fight. AEAT does not care whether the vendor misled you. It cares that you used the system. The practical lesson: verify the manufacturer's declaracion responsable yourself before you trust it.
The 50,000 EUR figure dominates the headlines. Several smaller fines sit underneath it and apply more often.
These layer with the Verifactu fines. They do not replace them. If you both fail to issue an invoice and your software is non-compliant, AEAT can apply more than one article in the same procedure.
Verifactu sits inside a broader anti-fraud architecture. If invoice manipulation also produces an under-declared tax liability, Articles 191 to 195 LGT add a surcharge of up to 75 percent on the unpaid tax. That is on top of the fixed Verifactu fine.
If the defrauded amount exceeds 120,000 EUR, Article 305 of the Codigo Penal opens criminal liability. This is no longer an administrative matter. It becomes a tax fraud case with potential prison time. Few autonomos hit that threshold. SLs with manipulated billing software absolutely can.
A freelance designer issues 60 invoices a year from an Excel template. From 1 July 2027, that template is not a SIF. Exposure: 50,000 EUR for the year, plus possible per-invoice fines. Recovery cost of switching to compliant software: under 200 EUR a year. The math is obvious.
A small consultancy SL runs an ERP installed in 2018. The vendor has not published a declaracion responsable. From 1 January 2027 the SL is exposed to 50,000 EUR per year while the vendor is independently exposed to 150,000 EUR. The SL cannot wait for the vendor to act. It must either pressure the vendor for a certified update or migrate.
A bar uses a POS terminal that prints tickets but cannot produce a hash-chained invoice. From 2027, every ticket issued as an invoice without a QR is at risk of the 150 EUR per invoice fine, plus the 50,000 EUR fixed fine for the underlying software. Hospitality is a top AEAT audit target. This is where enforcement will bite first.
If a propuesta de sancion arrives, do not ignore it. You have a 15-business-day window to file alegaciones. Article 188 LGT then offers two reductions that stack:
Combined, a 50,000 EUR fine can drop close to 21,000 EUR. That is still painful, but it is a 58 percent saving for acting fast and not litigating. The statute of limitations under Article 66 LGT is four years, so AEAT can come back as far as four ejercicios.
This is what a real gestoria does for you, and what software alone will not catch.
For a more technical walkthrough of the AEAT side, see our guide to [how Verifactu interacts with AEAT → getrenn.com/blog/verifactu-aeat], and our explainer on the [difference between Verifactu and the electronic invoice → getrenn.com/blog/difference-between-verifactu-and-electronic-invoice]. They are not the same regime, and confusing them costs people money.
50,000 EUR per fiscal year for the user, plus 150,000 EUR per product type per year for the software manufacturer. Both are independent and cumulative across years.
1 January 2027 for companies under Impuesto de Sociedades. 1 July 2027 for autonomos and other taxpayers. Voluntary use is open already.
Yes. The fine is fixed and not scaled to revenue. A low-revenue autonomo faces the same 50,000 EUR exposure as a large company. This is why early compliance matters more for small businesses, not less.
Yes. User and vendor liability are independent. AEAT fines you for using the software. You can pursue the vendor for civil damages separately.
No, not from your applicable 2027 date. Excel and Word are not Sistemas Informaticos de Facturacion. Using them after the deadline triggers the 50,000 EUR fixed fine.
Invoices issued before your mandatory date are valid for VAT deduction under the rules in force at the time. After the mandatory date, the recipient of a non-compliant invoice can have its deductibility challenged in an inspection.
No grace period is in the regulation. RD-ley 15/2025 already gave the market a one-year extension. Plan as if 1 July 2027 is hard.
Several ways: a routine inspection, cross-checks against the public list of compliant products, missing or invalid QR codes on invoices issued to customers in SII, or a tip from a competitor. Once you are flagged, the fixed fine applies even without a deeper audit.
