In this article, especially for freelancers and companies, we will see who should not use the new billing computer systems (IFS) to issue their invoices from 2026. I already tell you that they are few.
From 2026, companies must have their billing computer systems (IFS) updated in accordance with the new technical specifications that have been approved.
However, there are exceptions to this obligation…
If you are a self-employed entrepreneur, you will have started to hear the word Verifactu, SIF and for a long time electronic invoice.
The Treasury wants to control everything and be able to have the tools to collect the maximum.
If the treasury has an idea and wants to apply it, it first does tests and usually applies it to large companies and if it works, it applies it to the remains of small entrepreneurs and freelancers.
New Verifactu regulation
A few months ago, the technical specifications that the billing computer systems (SIF) must have were approved, with the aim of guaranteeing, among other aspects, the traceability and inalterability of the billing records.
The obligation to update the SIF according to these specifications will be enforcible from January 1, 2026 for IS taxpayers and from July 1, 2026 for the rest of the taxpayers.
However, some exceptions have been established. See them below.
What is Verifactu?
Verifactu is basically a system that allows you to know if you have modified or manipulated an invoice.
Who should not use a SIF (billing computer system)?
Taxpayers excluded from the obligation to use a SIF
Immediate supply of SII information
First of all, the new SIFs will not be enforcible to those companies that already keep their invoice register books through the Immediate Supply of Information (SII) system.
These companies are obliged to send to the Treasury electronically and almost immediately the details of their billing records (both issued and received) invoices, so they already meet the objective of greater control that is intended to be achieved with the new SIFs.
Companies and self-employed without economic activity.
Nor do personal income tax payers who do not carry out economic activities have this obligation.
For example:
- Real estate landlords who must declare their rents in the personal income tax as income from real estate capital, for not having workers.
Remember that the rental of real estate is not considered an economic activity, unless you have a hired person.
- Entities in an income attribution regime without economic activity (community of property, lying inheritances…).
Non-residents
Likewise, non-resident companies and entrepreneurs who carry out operations in Spain but without having a permanent establishment (EP) are exempt from this obligation.
If they have EP, they must comply with the new SIFs (in that case, they are taxed on the income obtained in Spain according to the rules of the IS).
What operations are excluded from using a SIF?
The farmers (what they lacked)
On the other hand, the new SIFs should not be used to register the operations carried out by entrepreneurs in the Special Regime for Agriculture, Livestock and Fisheries (REAGP) when they must issue a receipt for these operations.
However, the operations carried out by these entrepreneurs must be registered with the new SIFs when they are taxed in the personal income tax under a direct estimation regime or if they are operations for which they must issue an invoice (for example, if they make deliveries of real estate in which the VAT exemption has been waived).
Simplified regime and equivalence surcharge.
Likewise, it is not mandatory to register with the new SIFs the operations carried out by entrepreneurs who tax in equivalence surcharge or simplified VAT regime, unless they must issue an invoice.
See some cases in which these entrepreneurs must issue an invoice and, therefore, must register it with the new SIF:
- In both regimes, when the acquirer is another company or an individual who requests the invoice to be able to exercise some tax right.
- In the case of entrepreneurs under a simplified regime, when they transmit fixed assets (if an old van is sold, for example) or when the determination of the quotas accrued for current operations under that regime is made according to the volume of income.
- In the case of entrepreneurs in equivalence surcharge, when they tax in the personal income tax by the direct estimation regime, and in the deliveries of real estate that are subject and not exempt.
Summary of who should not use the new SIFs to bill in 2026
Companies hosted by the SII, lessors without economic activity and non-residents without PE are exempt from the new SIFs.
So are most of the operations carried out by entrepreneurs in REAGP, in simplified regime or in equivalence surcharge.
