On 7 September 2026, the DGT issued a binding consultation clarifying that tax advisory firms (gestorías) that exclusively perform bookkeeping and tax filing services for clients, but do not issue invoices on their behalf, are not required to use Verifactu-certified invoicing software. The Verifactu obligation applies only to those who issue invoices (the ‘obligated issuer’). Since the advisory firm acts as a mere intermediary transmitting data already generated by the client’s certified software, it does not need its own certified system. However, firms that generate invoices for clients must comply.
Key Takeaways
- Scope Clarification: The Verifactu mandate targets invoice issuers, not data transmitters acting on behalf of the issuer.
- Client Responsibility: The self-employed client remains responsible for using certified software to generate invoices.
- Cost Savings: Advisory firms avoiding invoice issuance can avoid software upgrade costs, but must ensure clients’ software is compliant.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement