Implementing Verifactu doesn't have to be overwhelming. Yes, there are technical requirements and deadlines to meet, but with a structured approach, most businesses can complete the transition smoothly. This checklist breaks down the process into manageable steps, so you can track your progress and make sure nothing falls through the cracks.
We've organized this into four phases: Assessment, Software Selection, Technical Implementation, and Go-Live. Work through them in order, and you'll be ready well before your deadline.
Phase 1: Assessment (Start Here)
Before you start evaluating software or planning technical changes, you need to understand exactly where you stand and what you're working with.
☐ Confirm your compliance deadline
Companies face a January 1, 2027 deadline; self-employed individuals have until July 1, 2027. Mark your specific date clearly and work backward from there. If you're a company, you effectively have less time than you think—accountants and software vendors will be swamped in late 2026.
☐ Check if you're exempt (SII users)
If your business is registered in the SII (Suministro Inmediato de Información) system—typically companies with revenue over €6 million—you're already exempt from Verifactu. Confirm with your accountant and save yourself the work.
☐ Document your current invoicing process
Map out how invoices flow through your business today. Who creates them? What software do they use? Where are records stored? How do invoices integrate with your accounting? This documentation will be invaluable when planning your transition.
☐ Inventory all invoicing software
You might be surprised by how many different tools are creating invoices in your organization. Excel spreadsheets, old desktop software, cloud apps, e-commerce platforms—list them all. Each one potentially needs to be addressed.
☐ Assign a project owner
Someone needs to be responsible for driving this project to completion. In small businesses, this is often the owner or financial manager. In larger companies, consider assigning a project manager with clear authority to make decisions.
☐ Create your implementation timeline
Work backward from your deadline. A realistic timeline for most businesses: 2 months for software selection, 2 months for implementation and testing, 1 month for training and parallel running, 1 month buffer. That's 6 months total—don't cut it closer.
Phase 2: Software Selection
This is where many businesses make mistakes—either by assuming their current software will be certified without checking, or by rushing into a decision without proper evaluation.
☐ Contact your current software vendor
Before looking elsewhere, ask your existing provider: "Will you have AEAT Verifactu certification, and when?" Get the answer in writing. If they're pursuing certification and will have it ready by mid-2026, you may not need to switch at all.
☐ Verify AEAT certification status
Don't take a vendor's word for it. Check the official AEAT registry of certified software. If they claim to be certified (or "certification pending"), verify it. Request their certification number and look it up.
☐ Evaluate mode support (VERI*FACTU vs NO VERIFACTU)
Decide which compliance mode you prefer. Most businesses opt for VERI*FACTU (real-time reporting) for simplicity. If you have specific privacy concerns, ensure your chosen software supports NO VERIFACTU mode.
☐ Check integration capabilities
Your invoicing software needs to work with your accounting system, ERP, CRM, and any other tools you use. Ask about APIs, pre-built integrations, and the vendor's experience connecting with your specific systems.
☐ Evaluate vendor support quality
When things go wrong—and they will at some point—you need responsive support. Test their support during your evaluation: call with questions, submit tickets, see how quickly they respond. Spanish-language support is essential unless you're comfortable troubleshooting in another language.
☐ Calculate total cost of ownership
Don't just compare subscription prices. Factor in implementation costs, training time, integration work, and potential productivity loss during transition. A slightly more expensive solution that's easier to implement might be cheaper overall.
☐ Request a trial period
Never commit to invoicing software without testing it first. Most vendors offer free trials. Use this time to create test invoices, verify QR codes work, test integrations, and get feedback from the people who'll actually use it.
Phase 3: Technical Implementation
Once you've selected your software, it's time to set everything up properly. Don't rush this phase—problems introduced here will haunt you later.
☐ Obtain your digital certificate
If you don't have one already, apply for a digital certificate from FNMT (Fábrica Nacional de Moneda y Timbre) or another recognized certification authority. This can take a few weeks, so don't leave it until the last minute. You'll need this to digitally sign your invoices.
☐ Configure your chosen mode
Set up the software in your preferred compliance mode (VERI*FACTU or NO VERIFACTU). If using VERI*FACTU, you'll need to configure the AEAT connection and test that records are transmitting correctly.
☐ Set up invoice numbering
Verifactu requires specific invoice numbering sequences. Work with your accountant to ensure your numbering scheme is compliant and consistent with your existing records. This is especially important if you're switching from another system.
☐ Configure invoice templates
Your invoices will now include QR codes and potentially VERI*FACTU labels. Work with the software to position these elements appropriately on your invoice templates. Ensure they don't interfere with your branding or other required information.
☐ Test QR code verification
Generate test invoices and scan the QR codes with your phone. Verify that they link correctly to AEAT's verification system (or your local verification in NO VERIFACTU mode). Do this with multiple invoices to ensure the hash chain is working.
☐ Migrate historical data (if applicable)
If you're switching systems, you may need to migrate customer data, product catalogs, and invoice history. Work with your vendor on the best approach—some data might be better archived in your old system rather than migrated.
☐ Set up backup procedures
Ensure your invoice data is being backed up regularly. For cloud software, verify your vendor's backup and disaster recovery capabilities. For on-premise solutions, implement your own backup strategy.
Phase 4: Go-Live Preparation
You're almost there. This final phase is about making sure your people are ready and your processes are solid before you start issuing real invoices.
☐ Train all invoicing staff
Everyone who creates invoices needs training on the new system. This isn't just about clicking buttons—they need to understand what Verifactu is and why certain processes have changed. Include your accounting team, sales staff who generate quotes-to-invoices, and customer service people who might need to explain QR codes to customers.
☐ Run parallel testing
If possible, run both old and new systems in parallel for a few weeks. Create invoices in both systems (don't actually send the duplicates) and compare them. This helps catch issues before they affect real customers.
☐ Update internal documentation
Update your procedure manuals, training materials, and any documented processes that involve invoicing. Future new hires will need this documentation.
☐ Prepare audit documentation
Organize your records: software certification documentation, digital certificate details, hash chain verification reports. When AEAT eventually audits you, you want everything at your fingertips.
☐ Establish support escalation procedures
Define what happens when something goes wrong. Who do staff contact first? When should they escalate to the software vendor? What happens if the AEAT connection fails? Have a plan before you need one.
Post Go-Live: The First Month
Congratulations—you've gone live with Verifactu. But don't relax completely yet. The first month is crucial for catching issues and establishing good habits.
Monitor invoice generation closely for the first few weeks. Check that QR codes are working, hash chains are intact, and staff aren't encountering unexpected issues. Have daily check-ins with your team initially, then scale back as confidence grows.
If you encounter problems, don't panic. Document the issue, contact your vendor support, and work through it methodically. Most issues in the first weeks are configuration problems that are easily fixed.