VERI*FACTU

Spain announces Verifactu postponement to October 2028: what changes and what doesn’t

Less than three months before companies have to invoice with a Veri*factu-compliant system, Spain’s Ministry of Finance (Hacienda) has announced its intention to move the calendar. According to its press release of 5 October 2026, it intends to move the outstanding obligations under the Regulation to October 2028, so that they coincide with mandatory e-invoicing for businesses and professionals with a lower volume of transactions.

The key lies in one detail: this is an announcement, not an approved rule. Until the amendment is published, the 2027 deadlines still apply. In this guide we explain exactly what the Ministry has said, which dates are in force today, what Veri*factu requires, how it differs from e-invoicing and how to use this extra time without taking anything for granted too early.

 

 

01. What exactly has the Ministry announced

The Ministry has stated its intention to align the calendar of the Regulation on computerised invoicing systems (Royal Decree 1007/2023, known as Veri*factu) with that of mandatory e-invoicing between businesses and professionals. The stated aim is to move the outstanding obligations under the Regulation to October 2028.


The Ministry also plans to address, at a later stage, an amendment to the scope and certain technical aspects, taking into account future EU digital reporting requirements (ViDA). At the same time, it has said that the core safeguards of the system (integrity, retention, accessibility, legibility, traceability and unalterability) will remain substantially equivalent.

Note: the announcement does not change the deadlines on its own

For October 2028 to become the new date, a legal amendment must be approved. Until that happens, the deadlines currently set by the Regulation remain fully in force. And the exact scope of the postponement (who it will affect and on what terms) will depend on what that rule says.

 

02. The deadlines that still apply today

Under the fourth final provision of Royal Decree 1007/2023, as worded by Royal Decree-Law 15/2025, the current deadlines are as follows:

Date Who Status
Before 1 January 2027
Corporate Income Tax payers
Current deadline (Royal Decree-Law 15/2025) until another rule is approved
Before 1 July 2027
All other taxpayers under Article 3.1 of the Regulation
Current deadline (Royal Decree-Law 15/2025) until another rule is approved
October 2028
Taxpayers subject to Veri*factu
Date announced by the Ministry, not yet approved
12 months after the ministerial order
B2B e-invoicing: volume of transactions above €8 million
Deadline set by Royal Decree 238/2026 (a separate obligation from Veri*factu)
24 months after the ministerial order
B2B e-invoicing: all other businesses and professionals
Deadline set by Royal Decree 238/2026 (a separate obligation from Veri*factu)

Software producers and vendors have their own adaptation deadline, linked to the entry into force of the implementing ministerial order. The Regulation also includes a specific rule for systems covered by multi-year maintenance contracts, so it is not accurate to say that all older software stopped being sellable on a single date.

 

03. Veri*factu and e-invoicing: two separate obligations

The Ministry’s announcement seeks to make the calendars coincide, but that does not turn both regimes into a single obligation:

  • Veri*factu (Royal Decree 1007/2023) regulates the records that the computer system you invoice with must generate, so that they cannot be altered without leaving a trace.
  • E-invoicing between businesses and professionals (Royal Decree 238/2026) regulates the issuing and transmission of invoices in electronic format, through the public solution or private platforms.

E-invoicing will be phased in, counting from the entry into force of its implementing ministerial order: 12 months for those whose volume of transactions exceeded €8 million in the previous calendar year, and 24 months for everyone else. Note that the criterion is the volume of transactions, not simply what you «invoice per year».

October 2028 is the date the Ministry has in mind to align Veri*factu with the lower-volume tier. But whether that alignment happens, and on what terms, will depend on the rule that is approved.

 

04. What Veri*factu is

Royal Decree 1007/2023 stems from Law 11/2021 on the prevention of tax fraud and sets out the requirements for the computer systems used to issue invoices. Its aim is for records to be complete, retainable, accessible, legible, traceable and unalterable, so that any modification or concealment does not go unnoticed.

The term «Veri*factu» also has a second meaning: it refers to the mode in which records are sent electronically to the Spanish Tax Agency (AEAT). Using a compliant system does not, by itself, require you to choose that sending mode.

 

05. Who is affected and who is exempt

Article 3 of the Regulation covers the following, when they use computerised invoicing systems:

  • Corporate Income Tax payers.
  • Those carrying out economic activities subject to Personal Income Tax (IRPF).
  • Non-Resident Income Tax payers with a permanent establishment in Spain.
  • Income attribution entities (entidades en régimen de atribución de rentas) that carry out economic activities.

A self-employed person’s method for calculating taxable income is not, by itself, an exemption. There are exceptions: among others, certain exempt entities and those who keep their record books through the Immediate Supply of Information system (SII). Article 4 also excludes certain specific transactions. The territorial application must be read with due regard to the regional (foral) tax regimes of the Basque Country and Navarre.

Be careful with «manual invoicing»:
Calling your invoicing «manual» is not enough to be exempt. A spreadsheet, a database or a word processor can be a computerised invoicing system depending on how you use them. What matters is how the data is issued, stored and processed, not the name of the tool.

 

06. Technical requirements: what will still apply

Under Article 8 of the Regulation, the system must:

  • Prevent original records from being altered without detection and allow their sequence to be followed.
  • Correct or cancel through a subsequent record that preserves the original: data already recorded is never overwritten.
  • Guarantee the retention, accessibility and legibility of the records.

There are two modes. In the mode with continuous sending to the AEAT (Veri*factu mode), the electronic signature of each record and the event log are not required on the same terms as in the mode without sending. If you do not opt for continuous sending, records must be retained and remain available for tax inspections.

Invoices issued with these systems include a QR code. It can make information or checks easier for the recipient, but it does not prove that the invoice has been sent to the AEAT: that depends on the mode used by the issuer.

According to the Ministry’s announcement, these core safeguards will remain substantially equivalent after the future amendment, although technical details may change.

 

07. How to choose invoicing software

The Ministry does not individually approve each program. What the Regulation provides for is a responsible declaration (declaración responsable) from the producer stating that its system meets the requirements. Before choosing, check:

  • That the producer provides the responsible declaration.
  • Which mode the program offers and how it will store or send the records.
  • How updates will be handled, since technical details may change.
  • If you will also be subject to e-invoicing, that the tool can be adapted to both obligations.

Bear in mind that having a tool for one of these functions does not automatically prove that you comply with the other: the records of the invoicing system are one thing, and the issuing and transmission of e-invoices is another.

 

08. Penalties: which conduct is penalised and the amounts

Article 201 bis of Spain’s General Tax Law distinguishes between two types of conduct: manufacturing, producing or selling systems in the prohibited cases, and possessing certain systems that do not meet the required certification conditions or whose certified devices have been altered. It does not set a generic fine for any user simply for using software that has not yet been adapted.

The amounts are fixed fines, not maximums:

  • €150,000 for each financial year in which there were sales and for each different type of system or program, in the general cases of manufacturing, production and sale.
  • €1,000 for each system or program sold without certification, where the infringement consists specifically of that lack of certification while being required to have it.
  • €50,000 per financial year for possessing systems in the cases set out in the law.

Applying each penalty requires identifying the specific conduct and the rules in force at that time.

 

09. Conclusion

As of 9 October 2026, October 2028 is an announced forecast for Veri*factu, not its new legal date. Until the amendment is approved, three things should be kept apart: the deadlines in force for those who use invoicing systems, the specific regime for producers and vendors, and the calendar for e-invoicing between businesses and professionals.

To stay on top of it, three steps are enough: follow the publication of the rule, check that your software has the responsible declaration and can be adapted to both obligations, and start working with records that are never overwritten as soon as possible.

Preparing your invoicing for both regimes is sensible. Treating them as if they were already a single obligation is not.

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