Verifactu for dental clinics: dates, duties and how to prepare

If you run a dental clinic in Spain, Verifactu is probably the regulatory change you have heard most about and found least clear information on. Most of what circulates is either alarmist marketing from vendors who want to sell you something, or summaries so generic that they never tell you what you have to do, in your clinic, this quarter.

This article tries the opposite: what Verifactu is, exactly when it binds you depending on how your clinic is set up, what you are entitled to demand from dental software, and which decisions are yours. At the end I explain how we solved it in Dently, but the article works just as well if you end up staying with the program you already have.

What Verifactu is, in one sentence

Verifactu is the popular name for the system that requires every invoice you issue to leave a trail that cannot be altered afterwards.

Until now, an invoicing program could let you delete an invoice, change its date or amount and print it again, leaving no trace. That is precisely what the rules target: so-called dual-use software, the kind that keeps two sets of books. The legislator’s answer was not to chase clinics one by one, but to change the rules for the programs themselves: if the software makes cheating impossible, the cheating disappears.

The real dates, by legal form

Two dates, and which one applies to you depends on how the clinic is incorporated, not on its size or turnover:

• 1 January 2027 if the clinic is a company.
• 1 July 2027 if the clinic is held by a sole trader.

During 2026 adoption is voluntary. That is worth reading twice, because both mistakes are common: nobody is obliged yet, and nobody is stopping you from getting ahead of it. If your clinic is a company, note that the shorter runway is yours.

Who is liable: you, not your software vendor

This is the part that gets lost in every sales conversation. The obligation to invoice through a valid system belongs to the taxable person, which is the clinic. The software manufacturer has its own separate duty: to issue a responsible declaration stating that its program complies.

So there are two documents and two responsibilities, and you need both. If your vendor slips into “don’t worry, we’ll take care of it”, ask which of the two they are talking about. A clinic that invoices through a non-compliant system does not get to point at the vendor afterwards.

Two modes: send or keep

The rules allow two ways of working, and for a dental clinic the choice is fairly clear.

Verifactu mode (sending). Your program transmits each invoicing record to the tax authority as invoices are issued. In exchange, your record-keeping duties are lighter, and the invoice carries a QR code the patient can use to check it.

Non-Verifactu mode (keeping). Nothing is transmitted, but your system must keep the records signed and available, with stricter traceability and event-logging requirements.

For a standard dental clinic, sending is almost always the sane option: it moves the burden of proof out of your office. Keeping only makes sense when there is a specific reason to avoid transmitting, and it is a heavier setup, not a lighter one.

The healthcare exemption does not get you out of it

A frequent and expensive misunderstanding. Most dental treatment is tax-exempt because it is healthcare, and many clinics conclude from this that invoicing rules do not concern them.

The exemption determines whether you charge tax, not whether an invoice exists nor which system issues it. An exempt invoice is an invoice. And purely aesthetic treatments — whitening, for instance — are not healthcare, so they are not exempt at all: they carry tax and they carry an invoice.

Is a dental clinic required to issue an invoice at all?

Worth answering separately, because many people assume it is always yes and many others always no. Neither is right.

The general rule is that a professional invoices their operations. The exception is that Spain’s invoicing regulation releases you from issuing an invoice for certain exempt operations, and healthcare provided to a private individual is one of them. But that release falls away in two very common situations in a dental clinic:

• The patient asks for it. And patients ask often: for their insurer, for reimbursement, or simply for the receipt. If they ask, you issue it.
• The recipient is not a private individual. If a company, another professional or an insurer is paying, always invoice.

Plus a third case that has nothing to do with the exemption: treatments that are not healthcare. Aesthetic work carries tax and carries an invoice.

The practical upshot is that most clinics end up invoicing almost everything, which is why it pays to stop treating the invoice as an exceptional front-desk errand and make it part of the normal patient circuit. That habit is also the best possible preparation for 2027: once the invoice already comes out of the same place as the accepted treatment plan, Verifactu stops being a project and becomes a configuration setting.

As with anything tax-related, check your own case with your accountant before changing how you invoice.

What your accountant handles, and what you have to handle

A lot of time gets wasted here, because the clinic assumes the accountant covers it and the accountant assumes the software does.

Your accountant can: confirm which date applies to you, review that your invoice series and numbering make sense before a chained system inherits them, tell you how exempt and non-exempt treatments play out in your particular service mix, and help with the tax authority authorisation if you decide your software should transmit on your behalf.

Your accountant cannot: make your current program generate chained invoicing records, sign the responsible declaration for the software, or absorb your liability.

In short: the accountant gives you the date and the criteria; the vendor gives you a date and the responsible declaration. If either is missing today, you know who to email this week.

Your plan, in five unhurried steps

1. Confirm your date. Company, 1 January 2027. Sole trader, 1 July 2027. Ask your accountant if in doubt.
2. Ask your current software in writing. Two things: whether it will issue invoicing records and in which version, and whether they will hand you the responsible declaration. Keep the answer.
3. Tidy your series and numbering now. A chained system inherits whatever disorder you hand it.
4. Choose the mode. Transmission or signed retention. For a standard dental clinic, the former.
5. Prepare the habit change. Under Verifactu, a wrong invoice is not deleted, it is corrected. That is the one change your front desk will genuinely feel, so tell them before day one.

How we solved it in Dently

Cards on the table, because on a topic like this transparency is worth more than a sale.

In Dently you can already issue patient invoices from the same place as your calendar and clinical records, starting from the treatment plan the patient accepted. Today the following works: each invoice generates a chained record with a SHA-256 hash, computed inside the same operation that issues the invoice; numbering is sequential per series with no gaps, guaranteed by the database itself; clinics in Spain get the tax authority verification QR code on the PDF; corrections are made through guided corrective invoices, with no delete button by design; and there is a full chain verification that recomputes every hash and detects any altered record or broken sequence.

And what is not switched on, said just as plainly: automatic transmission of records to the tax authority is built but disabled, pending completion of its validation against the authority’s test environment. We will switch it on when that validation closes, and the same goes for the system’s responsible declaration, which we will publish once signed. I would rather say it this way than hang a compliance badge on myself that I have not yet earned: anyone can type “Verifactu compliant” on a web page, and that does you no good at all on the day someone asks.

All of this is included in the 50 €/month + taxes subscription, with no separate module and no per-invoice fee. I don’t think anyone should charge extra for helping you meet a legal obligation.

If you want to see what a real invoice from your clinic looks like — your logo, your series, your treatments — you can try it free for 14 days.

And if you end up staying with your current vendor, at least now you know exactly what to ask them.

This article is general information, updated 11 September 2026, and does not replace advice from your accountant or tax adviser. The dates and requirements cited come from Spain’s Royal Decree 1007/2023, Order HAC/1177/2024 and Royal Decree-Law 15/2025; check your specific case before making decisions.