Invoicing with Excel: the great Verifactu dilemma

With only a few weeks until Verifactu becomes mandatory for businesses, the Spanish Tax Agency (AEAT) continues to fine-tune the regulation and address common questions. One of the most frequent concerns among freelancers, companies, and software developers is:

Can I still issue invoices using Excel, Word, or PDF without breaking the Verifactu rules?

The short answer: it depends. But there are important nuances.

What the Spanish Tax Agency says

According to the AEAT’s latest clarifications, the Verifactu regulation does not apply when word processors or spreadsheets are used only for:

• Entering invoice data
• Issuing and printing invoices
• Storing invoice information

In these cases, the tool is not considered an invoicing software system (SIF), and Verifactu does not apply.

However, the regulation does apply if you use Excel, Word, or any other program to process tax information, generate VAT or income tax ledgers, or automate accounting or billing records.

For example:

• If you manually enter data and only print invoices, Verifactu does not apply.
• If you use formulas, macros, or automations that generate accounting records, then you must comply with Verifactu.

It is also important to note that the AEAT can check at any time whether your use of these tools meets the technical definition of a SIF.

What this means in practice

This distinction creates a very fine line between what is allowed and what is not.

A professional using Excel purely to write and print invoices manually might be exempt, as long as there is no automation involved. But any formula, calculation rule, or macro effectively turns that sheet into a regulated invoicing system.

So, while AEAT has softened its position, in most real-world cases, the use of Excel will still fall under Verifactu. Especially if data is processed or stored in ways that impact tax compliance.

In short: ✅ You can use Excel or Word if you manually enter data without calculations or automation. ❌ You cannot use them if the file processes, calculates, or generates records automatically.

Key points to keep in mind

The crux of the issue lies in the definition of an Invoicing Software System (SIF). Although AEAT has provided examples, there are still gray areas. Where does manual editing end and automation begin? What level of calculation turns a spreadsheet into a SIF?

Imagine you’re a freelancer issuing invoices using Excel or Word. If you enter all the data manually —no formulas, no macros, no automations—, you would fall outside the scope of Verifactu. In other words, if you do your calculations by hand or with a desk calculator and only write down the final totals in the document, your invoicing method would be valid, just like using a traditional invoice book. 

But if, instead, you use a cell to multiply units by price, calculate the 21% VAT, or automate any part of the process, you’d already be using Excel as an invoicing software system (SIF). In that case, your method would not comply with the regulation and could expose you to fines of up to €50,000.

Given these ambiguities, it’s best not to assume. The interpretation will depend on each case, and AEAT may assess whether your system meets Verifactu’s technical requirements.

Don’t risk it: ask the experts

At fiskaly, we know tax regulations can be confusing, especially when they keep changing.

If you’re a company or freelancer, we recommend checking directly with the Spanish Tax Agency or with an invoicing software provider before continuing to use Excel or Word.

And if you’re a software developer or vendor, fiskaly SIGN ES can help you comply with Verifactu easily and at scale, ensuring your clients meet every regulatory requirement.

Our Verifactu API integrates seamlessly with any ERP or POS system and helps you comply with:

• The Anti-Fraud Law and Verifactu
• TicketBAI in the Basque Country
• NaTicket, the upcoming fiscal system in Navarra
• The Crea y Crece Law and mandatory B2B e-invoicing

All with a single integration and strict security protocols certified under ISO 27001 and ISO 9001.

Avoid the gray areas. Leave fiscal compliance to the experts and ensure your software and your clients’ stay fully compliant with Spanish tax regulations.