The short version

You are only off the hook if your spreadsheet does nothing but invoices: writing them, printing them and filing them. The moment it does anything more, the Tax Agency treats it as invoicing software. And almost everyone uses their spreadsheet for something more.

If your sheet keeps your issued-invoices ledger, produces your figures for forms 303 or 130, or has a macro that puts all of that together, for the Tax Agency it is invoicing software. And a spreadsheet cannot meet what the law requires of such a system.

“But I read that Excel isn’t affected”

It’s half true, and the missing half is the one that gets fined. In its FAQ, the Tax Agency says the regulation does not apply to spreadsheets used exclusively for three things: entering invoice data, issuing and printing invoices, and keeping them.

The moment the sheet does something more —producing the VAT or income-tax ledgers, the bookkeeping or other results to meet your tax obligations— it is covered. The Tax Agency gives the example itself: a simple list with its totals, no; a macro that builds your ledger, yes.

Now open your spreadsheet and ask yourself honestly:

• Do you have a tab with every invoice of the quarter that you use to prepare form 303?
• Do the base, VAT and withholding columns already give you the figures you copy into your tax returns?
• Is there a formula or macro that puts together the summary for your accountant?

If you answered yes to any of them, your spreadsheet is not “exclusively” making invoices.

Why a spreadsheet can’t comply

A VeriFactu-compliant invoicing system has to do things a spreadsheet can’t do, not even with the best template:

• One record per invoice, with a fingerprint chained to the previous invoice’s. If anyone edits, deletes or slips in an invoice, the chain breaks and it shows.
• No changes without a trace. In a spreadsheet anyone edits a cell and nothing is left behind.
• Send each record to the Tax Agency at the moment of issuing, in the VERI*FACTU mode.
• A QR code on every invoice that comes from that record. Your customer scans it and checks with the Tax Agency that the invoice exists.
• The statement of conformity from whoever makes the software, signing that all of the above is met.

The fine, no small print

It’s in article 201 bis of the General Tax Act, introduced by the 2021 anti-fraud law.

• Whoever has and uses a non-compliant invoicing system: a fixed €50,000 per financial year. It is not a maximum that gets scaled down: it is the amount.
• Whoever makes or sells that software: €150,000 per financial year and per type of software.
• It is a serious offence. And the obligation lies with whoever invoices, so “my accountant handles it” doesn’t cover you: your accountant isn’t the one with the spreadsheet.

The dates, after the postponement in Royal Decree-law 15/2025:

Your three ways out

1 · Make your spreadsheet only do invoices

You remove the summary tabs, the tax formulas and the macros, and keep the sheet for writing, printing and storing. Your accountant does the ledgers and the tax forms with their software. It’s legal, but you lose exactly what made the spreadsheet useful, and you pay someone to do it.

2 · The Tax Agency’s free app

It exists, it’s free and it has no invoice limit. It issues invoices and sends the records to the Tax Agency. If all you need is to invoice and comply, it’s an honest option and you should know about it. It’s built to issue and comply; everything around it —payments, expenses, preparing your taxes— you keep doing yourself.

3 · Compliant software that does what your spreadsheet used to do

This is where Factuza comes in. Every invoice goes out with its chained fingerprint, its QR code and sent to the Tax Agency on the spot. And what your sheet used to do still gets done, properly: drafts of forms 303 and 130 build themselves from what you invoiced, you track payments and expenses, and you hand your accountant the quarter’s package in a single file.

• €12 a month, excluding VAT, for the Self-employed plan, no lock-in. The first 20 customers pay €6 a month for the first year, no code needed.
• Your customers come from your spreadsheet: save it as CSV and bring them all in at once. Explained step by step in switching mid-year without repeating invoice numbers.

What to do this week

1. Open your spreadsheet and check whether it only makes invoices or also produces your ledger or your tax figures.
2. Note your date: 1 January if you are a company, 1 July if you are self-employed.
3. Choose your way out now, not in December. Switching software calmly takes an afternoon; switching in a rush means a week of badly issued invoices.