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VeriFactu Responsible Declaration of the Invoicing System

Last updated: June 11, 2026 · Download PDF (Spanish Official Text)

This statutory Responsible Declaration (Declaración Responsable) is issued pursuant to Article 13 of Royal Decree 1007/2023 of December 5 and Article 15 of Ministerial Order HAC/1177/2024 of October 17. It is available inside the application (Finance → Taxes → Compliance) and on this page.

Official Legal Language

The Spanish version is the reference text. An English translation is provided below alongside it.


RESPONSIBLE DECLARATION OF THE INVOICING SOFTWARE SYSTEM​

a) Name of the software system: Frihet

b) Identifier code of the software system: 01

c) Version of the software system covered by this declaration: 1.0

d) Components of the software system and description: Frihet is an invoicing software system composed of a single software component, with no specific hardware components: a software-as-a-service (SaaS) web application accessible at https://app.frihet.io, consisting of a web user interface and cloud processing and storage services managed by the producer. Its primary capabilities are issuing and managing invoices — including corrective invoices — quotes, expenses, clients, and products, as well as generating, for each invoicing operation, the registration and cancellation billing records required by the Regulation, with chained SHA-256 hash calculation, inclusion of the tax verification QR code on the invoice, and electronic submission of billing records to the electronic headquarters of the Spanish Tax Agency (AEAT) in a continuous, secure, accurate, complete, automatic, consecutive, instantaneous, and verifiable manner as a verifiable invoice issuing system (VERI*FACTU).

e) Indication of exclusive operation as VERI*FACTU: Yes. The software system has been designed so that, for the purposes of complying with the Regulation, it operates exclusively as a VERI*FACTU system in accordance with Section 2.6 of the Annex to Order HAC/1177/2024.

f) Indication of support for multiple taxpayers: Yes. The software system allows use by multiple taxpayers or by a single user supporting the invoicing of multiple taxpayers, in accordance with Section 2.6 of the Annex to Order HAC/1177/2024.

g) Signature types used to sign billing and event records when not operating as VERI*FACTU: Not applicable. The system operates exclusively as VERI*FACTU (see item e).

h) Producer of the software system: Víctor Berthelius, self-employed professional (profesional autónomo), marketing the system under the brand "Frihet".

i) Producer Tax ID (NIF): 54052380B

j) Producer contact postal address: Calle Cervera, n.º 9, Radazul, 38109, Santa Cruz de Tenerife, Spain.

k) Statutory compliance statement: The producer declares that the software system "Frihet", in version 1.0 indicated in this declaration, complies with Article 29.2.j) of Law 58/2003 of December 17 (General Tax Law), with the Regulation establishing the requirements to be adopted by computer or electronic systems and programs supporting the invoicing processes of businesses and professionals and the standardization of billing record formats, approved by Royal Decree 1007/2023 of December 5, with Ministerial Order HAC/1177/2024 of October 17, and with all specifications published on the electronic headquarters of the Spanish Tax Agency (AEAT) supplementing said Order.

l) Date and place of execution: June 11, 2026, Santa Cruz de Tenerife (Spain).


Annex — Additional Information (Article 15.2 of Order HAC/1177/2024)​

  • Additional contact channels: support@frihet.io
  • Producer Internet addresses: https://frihet.io (website) · https://docs.frihet.io (documentation, including invoicing system documentation) · https://app.frihet.io (application)
  • Summary of specification compliance: for every issued invoice, the system generates a high-registration billing record — and, where applicable, a cancellation record — with the content specified in Chapter II of Order HAC/1177/2024; computes the SHA-256 fingerprint of each record chaining it to the previous record (Article 8 of the Regulation); embeds the verification QR code with the AEAT verification service URL on every invoice; and transmits the billing records to the AEAT electronic headquarters via web service using an electronic certificate, operating as a verifiable invoice issuing system.
  • Retention of declarations: the producer retains the responsible declarations corresponding to all versions of the software system (Article 13.3 of RD 1007/2023). Declarations for prior versions may be requested at support@frihet.io.