Verifactu delay to 2028: what it means for businesses

October 13, 2026

Verifactu delay: the essentials at 8 October 2026

On 5 October 2026 the Ministry of Finance announced a Verifactu delay: it plans to move the pending obligations to October 2028, to align them with mandatory B2B e-invoicing for smaller businesses [1].
The announcement is a forecast: until a new rule is published in the BOE, the deadlines in force remain 1 January 2027 for companies paying corporate income tax and 1 July 2027 for everyone else [1][2][3].
Mandatory B2B e-invoicing started its clock on 6 October 2026, when Order HAC/1028/2026 took effect: businesses with turnover above 8 million euros have 12 months and the rest 24 months [5][6].
The Ministry says the integrity, traceability and inalterability requirements of the Verifactu regulation will stay substantially the same [1].
Holding non-compliant billing software is a serious offence with a fixed fine of 50,000 euros per year, and producing it is fined 150,000 euros [4].
Non-residents are covered only if they operate in Spain through a permanent establishment [2].

What the announcement changes, and what it does not

The Verifactu delay to 2028 has been widely reported as a done deal, but the legal position is more cautious.

The Ministry of Finance press note of 5 October 2026 describes a “forecast” of a change to the deadlines of the billing software regulation, Royal Decree 1007/2023 [1].

Until the Verifactu delay is approved and published in the BOE, the dates in the consolidated regulation still apply [2].

This guide explains the current rules, the proposed new timetable, the link with B2B e-invoicing and what businesses, self-employed professionals and foreign companies in Spain should do now.

The Ministry of Finance announced on 5 October 2026 its plan to postpone the pending Verifactu obligations until October 2028 [1].

What Verifactu is

Verifactu is the common name for the regulation on billing software approved by Royal Decree 1007/2023, which develops the anti-fraud rules added to the General Tax Law in 2021 [2][4][7].

It requires the software businesses use to issue invoices to guarantee the integrity, conservation, accessibility, legibility, traceability and inalterability of each billing record [2][4].

The Tax Agency describes two ways to comply [8]:

VERI*FACTU mode: the software sends each billing record to the Tax Agency, and the QR code on the invoice lets the customer check it.
Non-VERI*FACTU mode: records stay in the business’s own system, with an electronic signature, a hash chain and an event log, and must be available to the Tax Agency on request.

Invoices issued with a compliant system carry a QR code in either mode [8].

Who must comply

Article 3 of the regulation applies it to taxpayers who use billing software, even for only part of their activity [2]:

companies and other entities paying corporate income tax, except fully exempt entities;
self-employed individuals paying personal income tax on business or professional activities;
non-residents who obtain income in Spain through a permanent establishment;
entities under the income attribution regime, such as some partnerships, that carry on economic activities.

It does not apply to taxpayers who keep their VAT books through the Immediate Supply of Information system (SII) [2].

Some operations are also excluded, such as invoices issued through permanent establishments abroad and certain invoices issued by the customer or a third party [2].

The regulation also binds the producers and sellers of billing software, who must offer fully adapted products [2].

Self-employed professionals who are just starting out can read our guide to becoming self-employed in Spain, which covers registration and the invoicing basics.

The Verifactu delay: current and proposed deadlines

The table compares the dates in force with those announced, so you can see where the Verifactu delay would leave each group.

Group	Deadline in force (RDL 15/2025)	Announced on 5 October 2026
Corporate income tax payers	Systems adapted before 1 January 2027	October 2028 (not yet law)
Self-employed, permanent establishments, income attribution entities	Systems operational before 1 July 2027	October 2028 (not yet law)
Software producers and sellers	Adapted products within nine months of the technical order	Not specified in the note

Sources: Royal Decree 1007/2023, final provision four, as amended by Royal Decree-law 15/2025 [2][3]; Ministry of Finance note [1].

Royal Decree-law 15/2025, published on 3 December 2025, had already moved the deadlines to 2027, so this would be a further postponement [3].

Until a new rule appears in the BOE, corporate taxpayers must have compliant billing systems before 1 January 2027 [2][3].

Why the date is moving: B2B e-invoicing

The Ministry links the change to the calendar of mandatory electronic invoicing between businesses and professionals, so that both systems converge in law and in technical terms [1].

Law 18/2022 on business creation and growth extended the obligation to issue and send electronic invoices to all commercial relationships between businesses and professionals [9].

Royal Decree 238/2026, of 25 March, develops that obligation and sets its start dates by reference to a ministerial order on the public e-invoicing solution [5].

That order, Order HAC/1028/2026 of 2 October, was published on 5 October 2026 and took effect the next day, starting the countdown [6].

Business size (previous year’s turnover)	B2B e-invoicing applies
Above 8 million euros	12 months after the order took effect, so from October 2027
8 million euros or less, including the self-employed	24 months after the order took effect, so from October 2028

Sources: Royal Decree 238/2026, final provision four [5]; Order HAC/1028/2026, sole final provision [6].

The Verifactu delay to October 2028 matches the second group, which covers most small businesses and the self-employed [1][5].

Businesses with turnover above 8 million euros must issue B2B electronic invoices 12 months after Order HAC/1028/2026 took effect on 6 October 2026 [5][6].

How the public e-invoicing solution works

Order HAC/1028/2026 regulates the free public solution run by the Tax Agency [6].

Invoices follow the European standard EN 16931 in UBL syntax [6].
Businesses using private platforms must send the public solution a faithful copy of each invoice when it is issued [6].
Invoices are presumed accepted unless the customer rejects them or a corrective invoice follows [6].
Access requires an electronic certificate, and in some cases Cl@ve, and is free of charge [6].

Royal Decree 238/2026 excludes operations documented with simplified invoices, except qualified simplified invoices [5].

What the postponement means in practice

For most businesses, the Verifactu delay would mean one adaptation project instead of two, with billing software and e-invoicing introduced together.

The Ministry says the substance will not be diluted, because the integrity and traceability requirements will stay substantially equivalent [1].

It also plans a later change to bring the scope and technical aspects of Verifactu into line with the EU’s VAT in the Digital Age package (ViDA) [1].

The anti-fraud rules in the General Tax Law are not affected by the announcement: software that allows parallel accounts or the alteration of records is already prohibited [4].

Foreign companies and non-residents

A foreign company selling into Spain without a permanent establishment is not one of the taxpayers listed in Article 3, but it may still have Spanish VAT and invoicing obligations [2].

A branch or other permanent establishment in Spain is covered, so UK and other foreign groups with Spanish operations should include it in their plans [2].

Foreign groups setting up in Spain can compare the options in our guide to opening a branch of a UK company in Spain, and those selling without a base here should read about VAT registration for foreign businesses.

What to do now

These steps reflect the position after the Verifactu delay was announced and before any new rule is published.

Step	Action
1	Keep working to the 2027 deadlines until the BOE publishes a change
2	Ask your software provider whether the product is adapted and whether it will also handle B2B e-invoicing
3	Check your previous year’s turnover to see whether you fall in the 12-month or 24-month e-invoicing group
4	Confirm whether you use the SII, which takes you outside the Verifactu regulation
5	Obtain an electronic certificate for the company or professional if you do not have one
6	Review software contracts so the provider bears the cost of adaptation

A digital certificate in Spain is needed for the public e-invoicing solution, and our guide explains how to obtain one.

Common mistakes

Treating the October 2028 date as law before it is published in the BOE.
Stopping software adaptation projects already under way.
Assuming the e-invoicing deadline for large businesses has also moved to 2028.
Forgetting that a Spanish branch of a foreign company is covered.
Keeping old billing software that allows invoices to be deleted or altered without trace.

For broader advice on day-to-day compliance, see our guide to finding a good accountant in Spain.

How Delaguía y Luzón can help

Our tax law and accounting team in Valencia has advised businesses and professionals since 1960.

We review whether the Verifactu rules and B2B e-invoicing apply to you, follow the Verifactu delay timetable as it becomes law, and advise foreign companies and their Spanish branches on their invoicing obligations.

Speak to our tax team about Verifactu and e-invoicing

Contact our legal team for personalised guidance on your case.

We work in English, French, Spanish and Russian from our office in Valencia.

Email: felix.delaguia@delaguialuzon.com
Phone: +34 963 74 16 57
Office: Avinguda Regne de València, 6, 1º-2º, 46005 Valencia

Frequently asked questions about the Verifactu delay

Has Verifactu been postponed to 2028?

The Ministry of Finance announced the Verifactu delay on 5 October 2026.

It becomes binding only when a rule amending Royal Decree 1007/2023 is published in the BOE.

What are the deadlines in force today?

Before 1 January 2027 for corporate income tax payers and before 1 July 2027 for everyone else.

These come from Royal Decree-law 15/2025.

Why is Verifactu being postponed?

To align it with mandatory B2B e-invoicing for businesses with turnover of 8 million euros or less.

That obligation applies from October 2028.

When does B2B e-invoicing start?

Twelve months after 6 October 2026 for businesses with turnover above 8 million euros, and 24 months after for the rest.

The clock started when Order HAC/1028/2026 took effect.

Does Verifactu apply to the self-employed?

Yes, self-employed individuals carrying on economic activities are covered.

Those who keep their VAT books through the SII are not.

Does it apply to foreign companies?

Only to non-residents with a permanent establishment in Spain.

Other VAT and invoicing obligations may still apply.

Will the technical requirements change?

The Ministry says integrity and traceability requirements will stay substantially the same.

A later change will align the scope with the EU’s ViDA rules.

What is the penalty for non-compliant software?

A fixed fine of 50,000 euros per year for holding non-certified or altered systems where certification is required.

Producers and sellers face 150,000 euros per year and type of system.

Is the public e-invoicing solution free?

Yes, Order HAC/1028/2026 makes it free for users.

Access requires an electronic certificate, and in some cases Cl@ve.

Should I stop my software project?

No.

Keep working to the 2027 dates until a new rule is published, and plan to combine the work with e-invoicing.

References

Tax Law