VeriFactu in a transport company: what really changes when you invoice your haulage

First things first: VeriFactu does not replace the consignment note or the DeCA

It is the most common confusion in the sector, and it is understandable: in 2026 and 2027 three different digitalisation processes overlap, and all of them talk about QR codes. It is worth separating them once and for all, because they depend on different authorities and complying with one does not exempt you from the other.

In other words: the DeCA travels in the cab, VeriFactu stays in the office. If you are interested in the first, we cover it in DeCA mandatory from 5 October 2026. Here we deal with the second.

What VeriFactu is, in a haulier's words

Your invoicing software stops being a document editor and becomes a recorder. Every time you issue an invoice, the system generates in parallel a registro de facturación de alta (invoice issuance record), chains it to the hash of the previous record and — in VERI*FACTU mode — sends it to the Agencia Tributaria at that very moment. The legal basis is Real Decreto 1007/2023 (Royal Decree) and Orden HAC/1177/2024 (Ministerial Order), which sets the technical specifications.

The practical consequence fits on one line: an invoice that has been issued can no longer be changed. And in transport that collides head-on with a very widespread habit.

The end of a habit: “just go into the invoice and change the price”

In a haulage company, invoices are redone all the time. The customer disputes some waiting time, a mileage figure turns out to be wrong, the month's diesel surcharge is applied with a different index, or the head of planning realises the job went out at the old rate. Until now, the fix in almost any program was to open the invoice and correct the figure.

With VeriFactu that is no longer possible. Article 8.2.a) of the Reglamento (the Regulation) requires that, once generated and recorded, the data cannot be altered without the system detecting it, and that any correction be made through an additional, later record that leaves the original unchanged. In other words: a corrective invoice (factura rectificativa). And if the invoice should never have been issued at all, a registro de facturación de anulación (cancellation record, Article 11), which doesn't delete anything either: it records that the invoice was cancelled.

Once generated and recorded, they cannot be altered without the computer system detecting it.Real Decreto 1007/2023 — Article 8.2.a)

It is not a whim of the software: it is the declared aim of the law, to put an end to so-called dual-use software. For day-to-day planning, it means that checking prices and line items has to move before the invoice, to the transport order and the delivery note, because afterwards there is no quiet way back.

The case that hurts most: the monthly invoice grouped by delivery notes

Most transport companies don't invoice job by job: they add up the month's services and issue one invoice per customer, with the delivery notes or consignment notes behind each line. That model is still perfectly valid — VeriFactu does not require each shipment to be invoiced separately — but it changes where the point of no return lies.

• Before invoicing, delivery notes are internal documents: they can be corrected, moved to another customer or re-rated, and nothing happens.
• At the moment of invoicing, the issuance record is created with its hash. From then on, changing a delivery note that has already been invoiced doesn't fix the invoice: it requires a corrective invoice.

That is why the order of work matters more than ever: close the month's pricing, review it, and only then invoice. A good system should show you which delivery notes are still waiting to be priced before it lets you run the monthly invoicing, not after.

Shipper self-billing: who complies when you don't issue the invoice

It is common with large shippers, cooperatives and logistics operators: it is not the haulier who issues the invoice but the customer, who settles the month's haulage itself and sends you the finished document. The obvious question is whose obligation it is then.

Article 6 of the Regulation allows the obligations to be fulfilled by the recipient of the transaction or by a third party, but adds a caveat worth reading slowly: that does not exempt the taxpayer who provides the service. Put simply: even if the shipper physically issues the invoice, the haulier is not off the hook. If you work with self-billing, this belongs in the conversation with your customer before 2027, not after.

Several companies invoicing: series and numbering

Transport is full of groups with two or three companies — the haulage company, the one for the leased tank trailers, the one for the tank cleaning station — and with different invoice series by activity or by branch. VeriFactu doesn't prevent this. Each series keeps its consecutive numbering, as always, but the hash chain does not run per series: each company — each issuer tax ID (NIF) — keeps a single hash chain of its own, which runs through the records of all its series in chronological order, without mixing with those of the other companies (Article 2 of Orden HAC/1177/2024).

It is a detail that gets overlooked when choosing software and turns out to be expensive later: a system that treats the group's companies as a mere display filter, rather than as independent issuers with their own numbering and their own chaining, will give you a problem on day one. And if each company issues with its own certificate, that has to be configurable separately.

What your customer will see on the PDF

Two new elements: the first on every invoice, the second only in VERI*FACTU mode:

• A QR code on the invoice, with part of the document's content. Orden HAC/1177/2024 goes as far as requiring a size of between 30 and 40 millimetres and the ISO/IEC 18004 standard; the QR code carries the issuer's NIF (Spanish tax ID), the invoice number, the date and the amount.
• A legend, only if the system submits the records to the Agencia Tributaria (VERI*FACTU mode): the sentence “Factura verificable en la sede electrónica de la AEAT” (invoice verifiable on the AEAT's online portal) or “VERI*FACTU”. If it doesn't submit them, the invoice carries only the QR code, with no wording.

In VERI*FACTU mode, with that QR code your customer can check independently that the invoice you sent was actually reported. In practice, it is a seal of trust on your invoicing.

If you are in the SII, this doesn't apply to you

It is worth saying early on, because it affects many transport companies of a certain size. Article 3.3 of the Regulation excludes from these obligations those who keep their VAT record books through the Agencia Tributaria's online portal under Article 62.6 of the Reglamento del IVA (Spanish VAT Regulation): those under the Suministro Inmediato de Información (SII, Immediate Supply of Information). If your company is already in the SII — because of its turnover, because it is registered in the REDEME (monthly VAT refund register) or because it is taxed under the group regime — VeriFactu does not apply to you.

And if you aren't but are getting close to the threshold, it is worth doing the sums before investing in adapting anything.

“Software approved by the Spanish tax authorities” does not exist

You will see it in adverts and sales calls from now until 2027. There is no prior approval by the Agencia Tributaria. What the law requires is something else: a declaración responsable (statement of compliance) from the software producer (Article 13), issued for each version of the system, which must appear in writing and visibly within the program itself and be provided to customers and resellers.

It is the most useful question you can ask your supplier: show me the statement of compliance for the version I am using. If it exists, they will have it to hand and can give it to you as a PDF. If not, you know where they stand.

And it is no minor formality. Article 201 bis of the Ley General Tributaria (General Tax Act), introduced by Ley 11/2021, punishes anyone who manufactures or markets non-compliant programs with a fixed fine of €150,000 per financial year and type of system, and the mere possession of systems that are not certified when they should be with €50,000 per financial year. The second figure is aimed at the user, not the developer.

What to ask of your TMS before 2027

1. The statement of compliance for the specific version you use, with its system code and version identifier.
2. Issuance and cancellation records generated automatically on issue, not as a manual step someone might forget.
3. Verifiable chaining: you can check that the hash chain is intact, and the system warns you if it breaks.
4. Retrying after outages. The Agencia Tributaria's portal is not always available; the system must retry the submission on its own and keep a record, without blocking the day's invoicing.
5. Numbering and certificate per company, if you invoice from more than one.
6. Proper corrective invoices, with their reason and a link to the original invoice, instead of the old habit of reopening the document.
7. Invoices that come from the transport order: if the haulage, the mileage or the waiting time has to be typed in again, mistakes still get in, and now they can't be erased.