Everything about VeriFactu for lawyers in 2026: obligations, deadlines, technical requirements, penalties, VAT on legal services.
The VeriFactu system (RD 1007/2023) radically changes law firm invoicing. Every invoice must be generated through certified software guaranteeing integrity, traceability, and immutability.
System from RD 1007/2023 (Anti-Fraud Law 11/2021). Features: immediate registration, SHA-256 hash chain preventing retroactive alteration, verifiable QR code, impossibility of double bookkeeping.
All professionals issuing invoices (RD 1619/2012): self-employed lawyers, professional companies, collective firms, legal aid lawyers. Exception: SII taxpayers (>€6M turnover).
| Milestone | Date |
|---|---|
| RD 1007/2023 published | December 6, 2023 |
| Technical requirements | 2024 |
| Obligation for Corporate Income Tax taxpayers | January 1, 2027 (Royal Decree-law 15/2025) |
| Obligation for other professionals | July 1, 2027 (Royal Decree-law 15/2025) |
| Postponement to October 2028 | Announced by the tax authority on 5-10-2026, not published in the BOE |
Each invoice generates a record with: issuer tax ID, number/series, dates, type, tax base, VAT, recipient, SHA-256 hash of previous record (immutable chain), current fingerprint, verification QR.
VAT: legal services at 21% (Art. 90 LIVA). Exempt for non-EU clients (Art. 69 LIVA). Reverse charge for intra-EU businesses (Art. 84 LIVA).
Disbursements vs. Fees: Fees subject to VAT (21%) + tax withholding (15%/7%). Disbursements NOT subject to VAT (Art. 78.Three.3 LIVA): require: payment in client's name, prior mandate, invoice in client's name, transitory account.
Non-compliant systems (art. 201 bis LGT): up to €50,000/year for the user and up to €150,000 for the producer.
SHA-256 hash chain, verifiable QR, intelligent fee/disbursement separation, automatic VAT (21%) and tax withholding (15%/7%) calculation, immediate registration (AEAT submission starts with the firm's authorisation, through the Codelabs service), configurable series, PDF/XML/CSV export, case management integration.
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