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VAT and invoicing for digital products: what changes with Verifactu and OSS

Electronic invoicing is moving from optional to mandatory in Spain. Verifactu is the new regulatory framework requiring invoicing software to guarantee integrity, traceability, and inviolability of billing records. For digital-product sellers, that means adapting collection and invoicing systems.

Article

5

min read

2026

AtomicPay

01

Mandatory electronic invoicing is already here

Electronic invoicing is moving from optional to mandatory in Spain. The Verifactu system is the new regulatory framework requiring invoicing software to guarantee the integrity, traceability, and inviolability of billing records. For businesses selling digital products, that means adapting collection and invoicing systems to the new technical and legal requirements before the established deadlines.

Verifactu is not just a format change. It is a paradigm shift in the relationship between businesses and Spain's tax authority (Agencia Tributaria). Every invoice issued must be electronically verifiable, and invoicing programs must meet technical requirements that ensure records have not been tampered with. For digital-product sellers who issue hundreds or thousands of invoices a month, automating this process is critical.

02

VAT on digital products: the complexity of selling in Europe

When you sell digital products (online courses, software, ebooks, memberships, streaming) to end consumers in the European Union, digital-product VAT applies in the buyer's country, not yours. That means if you sell an online course from Spain to a customer in Germany, you must charge German VAT (currently 19%), not Spanish VAT (21%). And if you sell at the same time to customers in France, Italy, and Portugal, you must apply each country's VAT rate.

This rule, in force since 2015 for digital services, hugely complicates tax management for businesses selling across Europe. Without an automated system, calculating and declaring the correct digital-product VAT for every transaction in every country is an administrative nightmare that can consume hours of accounting work every month.

03

The VAT OSS regime: a one-stop shop to simplify

VAT OSS (One Stop Shop) is an EU mechanism designed to simplify VAT compliance on cross-border sales to end consumers. Instead of registering for VAT in every country you sell to, you register once in your country's VAT OSS (in Spain, through the Agencia Tributaria) and file a single quarterly return covering all your intra-EU sales.

VAT OSS does not remove the obligation to apply the buyer's country VAT rate, but it does remove the need to register with multiple tax administrations. That is a significant simplification that makes cross-border digital-product sales viable for small and mid-sized businesses that lack resources to manage tax obligations in 27 countries.

For your payment gateway to handle VAT OSS correctly, it needs to know the buyer's location and automatically apply the corresponding VAT rate. AtomicPay integrates location detection and automatic digital-product VAT calculation, so you charge the correct amount on every transaction without manual work.

04

Verifactu: what your invoicing system needs

The Verifactu system imposes several technical requirements on invoicing software. The software must generate a billing record for every invoice issued. Each record must include a chained hash linking it to the previous record, creating an immutable chain. The software must be able to send these records to the Agencia Tributaria automatically or make them available for verification on demand.

For digital-product sellers who issue invoices automatically with every purchase, that means the payment platform and invoicing system must be fully integrated and adapted to Verifactu. A manually generated invoice in a spreadsheet is no longer a viable option. You need a system that generates, numbers, records, and retains every invoice according to the new legal requirements.

05

Automation: the only way to comply without going crazy

If you sell digital products to consumers across Europe, the combination of VAT OSS, Verifactu, and electronic invoicing creates an administrative load that is only manageable with automation. Your flow should be: the customer buys on a landing page built with Atomicat, payment processes through your gateway, the system detects the buyer's country, applies the correct VAT, generates the Verifactu-compliant electronic invoice, and logs the transaction for the quarterly VAT OSS return — all without manual work.

If you also sell video content access through AtomicPlayer, integration between payment, invoicing, and content access must be automatic. The buyer pays, receives their invoice, and accesses content within seconds. Any manual step in this flow is a bottleneck that limits your ability to scale.

06

Deadlines and penalties: do not wait until the last minute

Mandatory Verifactu implementation dates vary by company size and type of tax obligation. Larger companies have nearer deadlines; smaller ones have a bit more time. Adapting electronic invoicing systems, however, is not a weekend project. It requires choosing or adapting compatible software, configuring invoicing flows, testing the system, and training your team.

Penalties for non-compliance are significant and can affect both sellers who do not issue compliant invoices and software developers who fail technical requirements. Do not wait until the obligation is imminent to act. Start evaluating options and planning the transition now.

07

Common mistakes in digital-product invoicing

The most frequent mistake is always applying Spanish VAT regardless of buyer location. If you sell an online course from Spain to a consumer in Germany, you must apply German digital-product VAT (19%), not Spanish (21%). The error may seem minor, but if the Agencia Tributaria finds you charged the wrong VAT for months or years, consequences include refunding overcharges, surcharges, and late-payment interest.

Another common mistake is failing to distinguish B2C from B2B sales. When you sell to another EU company with a valid VAT number, the transaction is VAT-exempt (reverse charge). If you do not verify the buyer's VAT number and apply VAT to an intra-EU B2B sale, you are charging a tax you should not and complicating both parties' accounting. Your electronic invoicing system should include a real-time European VAT number validator at checkout.

A third mistake is not retaining evidence of the buyer's location. For VAT OSS you need at least two independent proofs of customer location (IP address, billing address, card-issuing bank country, phone number country). Keep those proofs for at least 10 years, the period during which the tax authority can require them. Your payment gateway should record and retain this data automatically with every transaction.

08

Automating invoicing with Verifactu

Verifactu's entry into force in Spain requires businesses to issue electronic invoices that meet specific technical requirements. For digital-product sellers, that means your electronic invoicing system must generate invoices in a structured format, sign them electronically, and send them to the Agencia Tributaria automatically or on demand. The technical complexity is significant, and most small businesses will need to rely on certified invoicing software rather than managing the process manually.

The good news is that many payment gateways and ecommerce platforms are integrating Verifactu invoicing directly into their services. That means the invoice is generated automatically at payment time, with all correct tax data (digital-product VAT, buyer details, tax breakdown by destination country under the VAT OSS regime). Your work reduces to configuring tax parameters correctly once and periodically checking that invoices are being generated properly.

Do not wait until the last minute to adapt your system to Verifactu. Migration may require changes to your technology stack, compatibility testing, and a period of parallel operation with your current system. Start evaluating certified software options now and plan the transition with enough margin to resolve the technical issues that inevitably arise when implementing electronic invoicing.

09

Conclusion: tax compliance as an advantage, not an obstacle

Digital-product VAT, VAT OSS, and Verifactu can look like an unbearable bureaucratic burden, but they are actually an opportunity to professionalize your business and stand out from competitors. A robust, automated electronic invoicing system gives fiscal peace of mind, improves customer trust (they receive professional invoices instantly), and frees time to focus on what matters: selling and growing. The key is to automate as much as possible and integrate your payment gateway with your invoicing system from the start. Every manual invoice is an error risk and an unnecessary operating cost.