Your Spreadsheet Will Not Survive 2027: Migrating In-House Invoicing in Spain
If you issue Spanish invoices from Excel, a custom script, or a forgotten ERP screen, Verifactu treats that as billing software. Here is what must move, by when, and why implementers will be full before the deadline.
Your Spreadsheet Will Not Survive 2027: Migrating In-House Invoicing in Spain
US finance platforms tell banks they do not need to build a spend stack in-house. The Spanish version of that sentence is stricter. You are not choosing a convenience. Royal Decree 1007/2023 treats whatever you use to issue invoices as a Sistema Informático de Facturación (SIF). Excel with a macro is a SIF. A ten-year-old PHP form is a SIF. The till software you wrote in 2019 is a SIF.
If it cannot produce an immutable, hash-chained registration record and a QR code at the moment of issue, you are using non-compliant software. The fine is up to 50,000 EUR per fiscal year.
What Counts as In-House
| What you run today | Is it a SIF? | What happens in 2027 |
|---|---|---|
| Spreadsheet plus PDF | Yes, if you issue from it | Must migrate or stop issuing |
| Custom web form / ERP module you maintain | Yes | Must meet RD 1007/2023 or be replaced |
| Unmaintained vendor product with no Verifactu roadmap | Yes | Same fine. "The vendor vanished" is not a defence |
| Certified commercial SIF (or a product that is one) | Yes, and that is the point | Stay, or switch once |
| Handwritten tickets only | No SIF, but Verifactu and TicketBAI still constrain how you may invoice | Rare in shops that also sell online |
SII-enrolled taxpayers are exempt from Verifactu. They are not exempt from Crea y Crece. A homemade XML dump that satisfied SII will not satisfy hash chaining, QR, or the five-corner exchange. Two laws, two migrations, one calendar.
The Dates That Fill the Queue
Corporate income tax payers: 1 January 2027. Self-employed (IRPF) and others: 1 July 2027 (RD-ley 15/2025). Crea y Crece B2B issuance still runs on the ministerial order: October 2027 above 8 million EUR turnover, October 2028 for the rest.
Implementers (software houses, integrators, gestorías who still ship a billing tool) will be saturated in Q2 2027. That is not a marketing guess. It is what happens when a software obligation with a 50,000 EUR fine shares a year with a document-exchange obligation. If your migration starts after Easter 2027, you are bidding for leftover calendar.
What Must Move, Not What Must Look Pretty
A compliant SIF must, at issue time:
- Write a registration record that cannot be edited. Corrections are new records.
- Chain that record to the previous hash.
- Keep integrity, conservation, accessibility, legibility, traceability.
- Print a QR to the AEAT verification service on every invoice and ticket.
- Log starts, stops, errors, configuration changes.
- Answer AEAT queries.
Your spreadsheet has none of that. Exporting a CSV of historical invoices into a new product is not the hard part. The hard part is:
- Renumbering and series that must not collide with the old book
- TicketBAI regions (Bizkaia adds Batuz / LROE) if you operate there
- The 4-day status machine under RD 238/2026, which is a different project from the SIF
- Offline / incident mode so a dead line does not become illegal issuing
- Accountant access without giving away the keys
A Migration Order That Finishes
- Inventory the issuers. Tills, B2B screens, Amazon-to-invoice jobs, the owner's laptop. Every path that creates a number.
- Pick one SIF. Dual running two billing engines is how hash chains fork.
- Move master data first. Customers, tax IDs, series, IBANs. IBAN still lives on the vendor and customer record, not in a cell someone overtyped.
- Replay a month in parallel. Issue in the new SIF, keep the old system read-only. Compare totals with the gestoría.
- Cut over before the legal date, not on it. Leave a month for TicketBAI and AEAT test environments if you are in those scopes.
- Archive the old bytes. The new system does not rewrite history. The old files still have to be retrievable.
US "bill pay in a box" does not do this. A bank partnership does not do this. A card product does not sign Verifactu records.
Plandesk is the SIF for the shop and the restaurant: tickets at the till, B2B invoices from the same database, QR and hash on issue, export the gestoría already knows (A3). Spreadsheet cutover is a project with a date, not a feature toggle you leave for December 2026.
This material is information of a general nature and does not constitute legal or tax advice. For a specific situation, verify the current rules or consult a qualified adviser.