It depends on the model adopted, but the responsibility always falls on the invoice issuer, that is, your company or professional activity.
There are two possibilities:
Option 1: the issuer themselves uses a VERI*FACTU system
- The company’s computer system (ERP, billing software) already generates records in accordance with RD 1007/2023.
- In this case, nothing additional needs to be sent to the accounting firm, and if VERI*FACTU is used as the submission channel to the AEAT, the system sends it directly.
Option 2: the accounting firm manages the records
- If you provide the invoices in a structured and compatible format (registration records in accordance with Order HAC/1177/2024), the accounting firm can handle the submission to the AEAT for you.
- But your company remains legally responsible for ensuring that the submitted data is correct and that the source system meets the technical requirements.
Important:
- Submission through VERI*FACTU is voluntary, but the use of an adapted computer system will be mandatory in 2025/2026, even if the accounting firm later handles the data.
- It is not sufficient to issue in Word, Excel, or PDF: you must have a system that generates the technical record and preserves it correctly.
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