If you’re self-employed and use invoicing software, like the one we previously offered on our platform, this article is especially important for you.
You need to understand how the regulations are changing and what it means to keep using proforma or draft invoices. Even though Spain’s Tax Agency (AEAT) hasn’t published the final version of the e-invoicing regulation, they are sharing important points to keep you informed.
Here’s what you need to know…
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Proforma and draft invoices will still be valid, but you must keep them
Despite the increasing digitization and the upcoming implementation of mandatory e-invoicing in 2026, self-employed professionals can continue creating proforma or draft invoices. However, you must store these in your invoicing system as part of the record, just like final invoices.
The current regulations allow temporary entering or editing data or previewing an invoice. In fact, it’s completely valid to use a pre-invoicing system that lets you work with drafts or proformas. The key point is that these preliminary versions don’t include a QR code, which is the element that makes an invoice fiscally valid.
So even though you can send a proforma to a client before issuing the final invoice, the system must replace the draft with a valid invoice that includes its QR code once it creates the official version.
Do invoices always need to include a QR code?
Here’s the big question: Do your invoices always need a QR code? The short answer is no.
As we explained in this article on the VeriFactu system, the QR code is only required, for now, for those self-employed professionals who already use e-invoicing software.
For example:
Let’s say you’re a teacher registered in an exempt activity (not subject to VAT), and you issue around five invoices per month using a Word template, which you send as a PDF. You don’t submit quarterly tax returns and don’t use invoicing software. On top of that, your revenue is low.
In that case, you won’t be required to include a QR code in your invoices until next year, when mandatory e-invoicing comes into effect in July, via the new platform the Tax Agency plans to implement.
What happens when an invoice becomes final?
Once an invoice is officially issued, it must include a QR code and generate a signed invoice record. This is the document that gets submitted to the Tax Agency and, from that moment on, it can no longer be changed.
If you need to make changes, you can’t simply edit the original invoice. The only valid way to make corrections is to issue a new electronic invoice record, known as a corrective invoice, as defined by the regulation.
That means you should carefully manage proforma, and draft invoices right from the beginning.
Also, even if you have the QR code, that doesn’t mean you can skip saving drafts. Even if those drafts are later turned into final invoices, the Tax Agency is clear: you still need to keep them all.
E-invoicing adoption is growing, but there’s still time
Many businesses and freelancers are already adapting their systems to meet the new requirements, even though the authorities haven’t published the final regulation yet.
The use of e-invoicing grew by 35% in 2023 and 21% in the last year, surpassing 500 million e-invoices issued in Spain.
The Crea y Crece Law is partially responsible for this expansion; it requires all businesses and freelancers to use e-invoicing.
So far, only about a third of businesses have made the switch, but the change in attitude is clear. There’s growing concern and urgency, pushing many to adapt before the regulation becomes mandatory.
What should you do if you’re self-employed?
If you work with proforma or draft invoices and use online software for invoicing, here’s what we recommend:
- Make sure your invoicing software allows you to save these documents, even if they’re not fiscally valid yet.
- Properly link each draft or proforma with its final invoice in your system.
- Keep all records, even if your software is adapted to VeriFactu’s system.
- Avoid using online platforms that don’t meet the requirements set by the Tax Agency as penalties can be as high as €50,000.
In short, you can keep working the way you are, but you must properly document and organize everything.
The shift to e-invoicing isn’t just a technical one. It requires us to take greater responsibility for the way we manage our business documentation.
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