VeriFactu for holiday lets in Spain: who and when

VeriFactu is the nickname for a Spanish regulation that requires invoicing software to keep a tamper-proof record of every invoice it issues, with a chained fingerprint (hash) and a QR code that customers can check with the Spanish Tax Agency (Agencia Tributaria, or AEAT). If you own a holiday let in Spain, the real question is not whether you own property there, but whether your letting counts as a business activity and whether you invoice with software.

Where things stand on 11 October 2026: the legal deadlines are still 1 January 2027 for companies and 1 July 2027 for everyone else who is caught. On 5 October 2026 the Ministry of Finance announced it intends to push this back to October 2028, but that change has not yet been published in the Boletín Oficial del Estado (BOE), Spain's official gazette.

What VeriFactu is

The legal basis is Royal Decree 1007/2023, which approves the regulation on invoicing software requirements (known in Spanish as the RRSIF). The technical detail sits in Order HAC/1177/2024: record formats, how the hash is calculated, what the QR code looks like and how data is sent to the AEAT.

The principle is simple. Each time your software issues an invoice, it also creates an invoicing record with the key data: the issuer's tax number (NIF), invoice number, date, invoice type, VAT amount and total. That record is "sealed" with a hash that also depends on the previous record's hash, so if anyone deletes or edits an old invoice, the chain no longer adds up.

There are two ways to comply:

• VERI*FACTU mode: the software sends each record to the AEAT as it is created. The invoice carries the wording "Factura verificable en la sede electrónica de la AEAT".
• "Non-VERI*FACTU" mode: the software keeps the records itself, available to the tax authorities, with extra security requirements: each record must be electronically signed (XAdES signature, article 14 of the order) and the software must keep an event log (article 9 of the order: start and end of this mode, anomaly detection, exports, backup restores and a summary at least every 6 hours of operation). The invoice still carries the QR code, without that wording.

Does it apply to your holiday let?

The AEAT sums up the scope with its "four NOs" rule: you are caught if you issue invoices with software (not only by hand), you are not on the SII real-time VAT reporting system, your tax domicile is not in the Basque Country or Navarre, and you have no exemption ruling. On top of that, the regulation only covers companies, Spanish income-tax payers carrying on a business activity, and non-residents operating through a permanent establishment in Spain.

For holiday lets that gives these common cases:

Most foreign owners with one or two flats fall into the last two rows: you hand over keys, clean between guests and declare the income as property income, either in your Spanish income-tax return if you are resident or on form 210 (non-resident income tax, IRNR) if you are not. We explain the resident side in how to declare holiday rental income. Note that being outside VeriFactu does not mean you never have to issue invoices; it only means your software does not need to meet these rules.

Deadlines currently in force

The timetable has moved several times:

1. Royal Decree 254/2025 set 1 January 2026 for companies and 1 July 2026 for everyone else.
2. Royal Decree-law 15/2025 of 2 December pushed it back a year: 1 January 2027 for corporation-tax payers and 1 July 2027 for the rest (self-employed people and non-residents with a permanent establishment). These are the dates the AEAT shows today.
3. On 5 October 2026 the Ministry of Finance issued a press note announcing a postponement of the outstanding obligations to October 2028, so they coincide with mandatory B2B e-invoicing for businesses with turnover up to €8 million. It says the integrity, retention and traceability requirements will stay "substantially equivalent".

Until that postponement is approved and published in the BOE, the 2027 dates remain the law. It is sensible to keep preparing: the timetable is moving, not the substance.

What your invoicing software has to do

Compliant invoicing software must, at a minimum:

• Create a registration record for each invoice issued and a cancellation record when one is cancelled, with the fields set by the Order.
• Calculate a SHA-256 hash for each record, chained to the previous one, so the history cannot be altered unnoticed.
• Print a QR code on the invoice (between 30x30 and 40x40 mm under article 21 of the order; the AEAT's technical specification adds the label "QR tributario:"), linking to the AEAT's checking service with the issuer's NIF, invoice number, date and amount.
• Not allow issued invoices to be deleted or edited: mistakes are fixed with a corrective invoice (factura rectificativa).
• Depending on the mode: send records to the AEAT (VERI*FACTU) or keep them with an electronic signature alongside an event log (non-VERI*FACTU).
• Come with a statement of compliance (declaración responsable) from the software maker.

The AEAT also offers a free invoicing application on its website, an option if you issue few invoices and need nothing else.

What Apartop does with your invoices

In Apartop, "Invoices issued with a chained hash and QR code" is part of the Pro plan (see pricing). This is exactly what it does today:

• It invoices each booking with the guest details from online check-in, the dates and the amount already filled in, with sequential numbering by series, full or simplified invoices and corrective invoices (how it works).
• Each invoice gets a record with a SHA-256 hash chained to the previous one for the same owner, calculated to the AEAT's technical specification. If you delete the latest invoice by mistake, a cancellation record is kept. In settings you can check that each owner's chain is intact.
• The invoice carries the "QR tributario" linking to the AEAT's checking service.
• It stores the records and does not send them to the AEAT, as in non-VERI*FACTU mode, which is why invoices do not carry the "VERI*FACTU" wording.

What it does not do yet, and you should know: Apartop does not currently send records to the AEAT, does not electronically sign the records or keep the event log that non-VERI*FACTU mode requires, and has not yet published its statement of compliance. Nothing is mandatory yet (the dates are in 2027), but before the date that applies to you, ask your software provider (Apartop or any other) for its statement of compliance, and agree the right mode with your adviser.

Apartop also lets you set the VAT treatment for each owner (exempt, 10% or 21%) and separates the platform commission as an expense. Invoices you receive (cleaning, utilities, repairs) are handled by another feature: expenses from a photo of the invoice.

VAT on holiday lets and how it links to VeriFactu

VeriFactu does not change the VAT you charge (IVA in Spanish); it only governs how invoices are recorded. But the two overlap, because VAT treatment often signals whether your letting is a business activity:

• No hotel-style services: letting a furnished home is currently VAT-exempt (art. 20.Uno.23 of the VAT Act, Law 37/1992).
• Hotel-style services (mid-stay cleaning, linen changes, restaurant…): 10% VAT, and it is a business activity for income tax, which brings you into VeriFactu.

New: Royal Decree-law 29/2026, published in the BOE on 7 October 2026, removes the exemption from 1 December 2026 for furnished lets of 30 nights or fewer (unless it is in the landlord's own main home) and moves them to 10% VAT (new wording of article 20.One.23, letter e', and article 91.One.2.2 of the VAT Act). A royal decree-law must be ratified by the Congress within 30 working days or it is repealed; with Parliament dissolved for the 29 November election, the vote falls to its Standing Committee (Diputación Permanente). As of 11 October 2026 it has not yet been voted on. Charging VAT does not by itself make your letting a business activity for income tax, so it does not automatically bring you into VeriFactu. If you are a non-resident, VAT registration may also mean appointing a tax representative or adviser in Spain: take advice before 1 December.

For other local taxes, see tourist tax by region in 2026.

Penalties

Article 201 bis of the General Tax Act penalises:

• Using an invoicing system that is not properly certified when it must be, or that has been altered or modified: €50,000 per tax year.
• Producing or selling non-compliant systems: €150,000 per tax year per type of system, plus €1,000 for each system sold without the required certification.

That is why it matters that your software has its statement of compliance, and why, if you are caught, an editable spreadsheet that lets you rewrite past invoices is not a safe option.

What to do now

1. Ask your adviser whether your letting is a business activity (hotel-style services, staff) or simple property income.
2. If you are a company or self-employed with hotel-style services, choose ready software now and start invoicing with sequential numbering.
3. Review your VAT position ahead of 1 December 2026 and watch whether Royal Decree-law 29/2026 is ratified.
4. Follow the AEAT's VeriFactu page to see whether the 2028 postponement reaches the BOE.

If you want to try booking invoices, you can create a free account: new accounts get 30 days of Pro. And don't forget the other paperwork for your flat, such as your regional tourist licence (and what is left of the Single Rental Register after it was annulled).

Sources

Official sources accessed 11 October 2026.

• Royal Decree 1007/2023, invoicing software regulation (BOE)
• Order HAC/1177/2024, technical specifications: arts. 6, 9, 14, 20 and 21 (BOE)
• Royal Decree 254/2025 of 1 April (BOE)
• Royal Decree-law 15/2025 of 2 December, ratified by Congress (Resolution of 11 December 2025) (BOE)
• Ministry of Finance press note, 5 October 2026 (announcement, not yet law in the BOE)
• Order HAC/1028/2026, public e-invoicing solution (BOE, 5 October 2026)
• AEAT: invoicing software and VERI*FACTU
• AEAT: FAQs on scope ("rule of the 4 NOs", rentals)
• Law 58/2003, General Tax Act, art. 201 bis (BOE)
• Law 37/1992, VAT Act (BOE)
• Royal Decree-law 29/2026 of 6 October, art. 7 (BOE, 7 October 2026)
• Royal Decree 806/2026, dissolving Parliament (BOE, 6 October 2026)