Verifactu delayed to 2028? Not yet

What is law today and what to do if you are starting now

On 5 October 2026 Spain’s Ministry of Finance published a press note with a sentence that, within days, became a headline across half the internet: the outstanding Verifactu obligations would be postponed until October 2028.

Many articles report it as if it were already law. It is not.

Today, 14 October 2026, the binding deadline is the one published in the Spanish Official Gazette (BOE), and it is still 1 January 2027 for companies and 1 July 2027 for the self-employed. The Spanish Tax Agency (AEAT) still shows those dates on its Verifactu page, updated on 7 October. What exists on top of that is an announcement that they will change.

The difference matters if you are about to set up a company or register as self-employed (autónomo) in Spain: you are choosing now the software you will invoice with for years.

What Verifactu is, in two paragraphs

Verifactu is the common name for Spain’s Regulation on invoicing software systems, approved by Royal Decree 1007/2023. It requires the software that businesses and the self-employed use to issue invoices to meet certain technical standards: each invoice must create a record that cannot be deleted or altered without leaving a trace, chained to the previous one by a digital fingerprint (hash), and the invoice must carry a QR code.

The software can work in two modes. In VERI*FACTU mode it sends each record to the Tax Agency as the invoice is issued. In non-VERI*FACTU mode it keeps the records with stricter security requirements (an electronic signature on each record and an event log) and makes them available if the Tax Agency asks.

What is law today

The deadlines in force

Royal Decree-law 15/2025 of 2 December (BOE of 3 December) pushed the original deadlines back by one year. It was validated by Parliament on 11 December 2025 (resolution published in the BOE on 16 December), so it is fully in force. Under the fourth final provision of Royal Decree 1007/2023, as worded by that decree-law:

Who	Deadline to have compliant software
Corporate income tax payers (SL, SA and other companies)	Before 1 January 2027
Everyone else: self-employed people paying personal income tax on a business activity, non-residents with a permanent establishment, and partnerships such as comunidades de bienes	Before 1 July 2027

The Tax Agency explains in its note on the extension that the period before each date works as a testing period.

Who has to comply

The Tax Agency sums it up in what it calls the “four no’s” rule. Verifactu applies to you if:

You do not invoice exclusively by hand.
You are not in the SII (Spain’s immediate VAT reporting system).
Your tax address is not in the Basque Country or Navarre, which have their own systems.
You do not have a valid exemption resolution.

Two nuances that are often missed. First, Word and Excel can count as invoicing software. If you only use them to type and print invoices, the Tax Agency does not treat them as an invoicing system; but if they process that information to automatically produce your sales ledger, your accounts or other outputs (for instance with a macro), they do. Second, if your accountant or another third party issues invoices for you, whoever physically issues them must comply, but that does not remove your own responsibility.

What non-compliance costs

Article 201 bis of the General Tax Act punishes the use of invoicing systems that do not meet the requirements with a fixed fine of 50,000 euros per financial year. For those who make or sell non-compliant software, the fine is 150,000 euros per year. It is not proportional to your turnover: it is the same for a sole trader as for a large company.

What is only an announcement

The Ministry of Finance note of 5 October 2026 says three things:

That it plans to change the deadlines for the outstanding obligations under Royal Decree 1007/2023 and move them to October 2028.
That the aim is to align them with mandatory e-invoicing for businesses and professionals with an annual turnover of up to 8 million euros.
That the substantive requirements (integrity, retention, accessibility, legibility, traceability and unalterability of records) will remain substantially equivalent, and that a later amendment will bring the two systems together and adapt them to future EU digital reporting rules (the package known as ViDA).

What the note does not say: which legal instrument will be used, when it will be approved, or whether the new date will be the same for companies and the self-employed. It refers generally to “businesses and professionals”. Until that rule is published in the BOE, the 2027 deadlines are the only enforceable ones.

Why 2028: e-invoicing already has a date

The announcement follows a logic worth understanding, because it will probably shape the final calendar.

Mandatory business-to-business e-invoicing (introduced by Spain’s Crea y Crece law) is now fully regulated. Royal Decree 238/2026 of 25 March sets up the system, and Order HAC/1028/2026 of 2 October, published in the BOE on 5 October and in force since the 6th, regulates the public e-invoicing platform and starts the countdown. According to the Tax Agency:

Date	Who
6 October 2027	Businesses and professionals with turnover above 8 million euros: issue, send and receive e-invoices, and report invoice and payment status
6 October 2028	All other businesses and professionals: issue, send and receive e-invoices. Companies up to 8 million euros also report invoice and payment status
6 October 2029	Individuals and partnerships: report invoice and payment status

In other words, the publication of that order set October 2028 as the e-invoicing date for small businesses and the self-employed, and the Ministry announced the same day that it wants Verifactu to coincide with it. It makes sense: forcing businesses to adapt their software in 2027 and change it again in 2028 would mean paying twice for the same transition.

What to do if you are starting now

If you are setting up a company or registering as self-employed in the coming months, the delay changes little. These are the reasons.

1. Choose compliant software from day one. No new software you sign up for today should be left outside Verifactu, delay or no delay. If you choose one that is not compliant, you will have to migrate, and migrating an invoicing system once the business is running (series, clients, templates, payment gateway integrations) costs more than choosing well on day one.

2. Ask for the producer’s statement of compliance. The Tax Agency does not certify software: the producer declares, under its own responsibility, that the software complies (a declaración responsable). “Verifactu-ready” on a sales page is not the same thing. If you sell online, also check that the software integrates with your payment gateway and can issue a full or simplified invoice depending on the customer.

3. Think about e-invoicing now. What is not going to move is mandatory e-invoicing in October 2028. The software you choose should cover both, or have a clear plan to do so.

4. Do not switch on VERI*FACTU mode live without thinking it through. Once you start sending records to the Tax Agency, you stay in that mode at least until the end of that calendar year. That is not a problem if you will be obliged anyway, but test first in a test environment and decide calmly. That is how we did it when we implemented it in our own practice: first in a test company, then in the live one.

5. If you have already adapted, do not undo anything. According to the Ministry’s own note, the substantive requirements will stay “substantially equivalent”. The work you have done is not lost.

For a company being set up now, this fits in with the rest of the steps after the notary. And if you work in construction, there is an extra reason to get invoicing right from the start: the VAT rules for self-employed builders and renovation trades have enough traps already.

What we have seen with clients this month

In recent weeks we have worked on this with two very different profiles. For a company selling digital products to customers worldwide, the problem was not Verifactu itself but that its online sales platform did not issue invoices that met Spanish rules, so it needed a tool that invoices every sale at the moment it happens, in the right format and connected to the payment gateway. In our own practice, we implemented Verifactu in our management software, testing issuing, corrective invoices and cancellations in a test environment first.

In both cases the conclusion was the same: the exact date matters less than reaching it with the software already chosen and tested.

What we do at Stoa

At Stoa we review how your business invoices, which software you need for your volume and sales channels, and how it fits with your accounts, so that the 2027 or 2028 change does not catch you halfway. If you are setting up your business, we sort it out from day one as part of the launch. It is a small part of what an outsourced finance director does, but one of the most expensive to fix late. We work in English and Spanish from Málaga.

Want us to look at your case? Get in touch.

Frequently asked questions

Has Verifactu been delayed to 2028?

Not yet. On 5 October 2026 Spain’s Ministry of Finance announced that it plans to postpone the outstanding Verifactu obligations to October 2028, to align them with mandatory e-invoicing. Until that change is published in the BOE, the deadlines set by Royal Decree-law 15/2025 remain in force: 1 January 2027 for companies and 1 July 2027 for everyone else.

When is Verifactu mandatory for Spanish limited companies?

Under the rules in force on 14 October 2026, corporate income tax payers must have compliant invoicing software before 1 January 2027, under the fourth final provision of Royal Decree 1007/2023 as amended by Royal Decree-law 15/2025.

When is Verifactu mandatory for the self-employed in Spain?

For self-employed people paying personal income tax on a business activity, and other taxpayers outside corporate income tax, the current deadline is before 1 July 2027. The Ministry has announced plans to move it to October 2028, but the rule has not been approved yet.

What is the fine for not complying with Verifactu?

Article 201 bis of Spain’s General Tax Act sets a fixed fine of 50,000 euros per financial year for using invoicing systems that do not meet the requirements. For producers and sellers of non-compliant software, the fine is 150,000 euros per year.

Does Verifactu apply if I invoice with Word or Excel?

It depends on how you use them. According to the Tax Agency, if they are only used to type, issue and print invoices, they are not an invoicing system. If they process the information to automatically produce ledgers, accounts or other outputs, for example with macros, they are, and they must comply.

When will B2B e-invoicing become mandatory in Spain?

Order HAC/1028/2026, in force since 6 October 2026, started the countdown under Royal Decree 238/2026. According to the Tax Agency, the obligation starts on 6 October 2027 for businesses with turnover above 8 million euros and on 6 October 2028 for all other businesses and professionals.

If I set up my business now, what invoicing software should I choose?

One that is already Verifactu-compliant and prepared for e-invoicing, backed by the producer’s statement of compliance. The Tax Agency does not certify software: the producer declares that it complies. Choosing well from the start avoids migrating the system once the business is running.