Verifactu has been postponed so often that most business owners we talk to have stopped listening. That's understandable, and a bit risky, because the dates that are actually law haven't moved since December 2025.
This isn't legal or tax advice, and we're not gestores. It's the practical orientation we give clients who invoice through software, with a link to the official source for every date. For your own situation, ask your gestor.
What is Verifactu, in plain terms?
Verifactu is the common name for the rules in Real Decreto 1007/2023 on invoicing software, the Reglamento de sistemas informáticos de facturación. The idea is simple: if you invoice with software, that software has to keep a record of every invoice that can't be quietly changed or deleted afterwards.
The Agencia Tributaria describes two ways a program can comply:
- VERI*FACTU mode. The software sends each invoice record to the Agencia Tributaria automatically, as you invoice. The tax agency then holds the records, so you don't have to guarantee their custody yourself.
- Non-VERI*FACTU mode. The software doesn't send anything, but keeps the records itself, electronically signed, with an event log, and has to be able to export them on request.
Every invoice issued with software in scope carries a QR code, whichever mode you use. In VERI*FACTU mode the invoice also carries the legend "VERI*FACTU" or "Factura verificable en la sede electrónica de la AEAT", and your customer can scan the QR to check that the invoice is registered with the tax agency.
Who has to comply?
According to the Agencia Tributaria, the rules cover businesses and professionals who pay personal income tax (IRPF) on an economic activity, companies that pay corporate tax (Impuesto sobre Sociedades), and non-residents with a permanent establishment in Spain, when they are based in the common tax territory.
Excluded:
- Businesses that use the SII (Suministro Inmediato de Información). The two systems are mutually exclusive.
- Businesses taxed under the foral regimes of the Basque Country and Navarre, which have their own systems.
- Operations that don't require an invoice.
The rules are about invoicing software. The Agencia Tributaria's FAQ says that someone who issues invoices entirely by hand isn't affected, and that a word processor or a spreadsheet used only to type and print invoices isn't a billing system either. A spreadsheet with macros that generates your invoice register is. If you're on the edge, check the FAQ with your gestor.
When does it apply? Law versus announcement
This is where most of the confusion comes from, so here it is in two parts.
What is law today
Real Decreto-ley 15/2025, published in the BOE on 3 December 2025, rewrote the deadlines in Real Decreto 1007/2023:
- Companies that pay corporate tax: systems adapted before 1 January 2027.
- Everyone else in scope, including autónomos: systems operational before 1 July 2027.
The Agencia Tributaria's own note on the extension, updated on 13 October 2026, still gives these two dates. The consolidated text of Real Decreto 1007/2023 in the BOE shows them too.
Software makers were on a different clock. They had to offer adapted products within nine months of the ministerial order that set the technical details, Orden HAC/1177/2024, coming into force on 29 October 2024. That deadline was 29 July 2025, and it has not been moved.
What has been announced
On 5 October 2026 the Ministerio de Hacienda published an informative note saying it intends to postpone the pending Verifactu obligations to October 2028, so that they coincide with mandatory B2B e-invoicing for businesses with up to 8 million euros of annual turnover. The same note says the technical guarantees of Real Decreto 1007/2023 (integrity, traceability, inalterability and the rest) will stay in substantially equivalent terms.
An announcement is not a law. As of 19 October 2026 we have not found any rule in the BOE that changes the 2027 dates. Hacienda's own note calls itself a previsión. Some software vendors already present October 2028 as fixed. Until a new rule is published in the BOE, 1 January 2027 and 1 July 2027 are the dates in force. We'll update this article when that changes.
Our advice to clients is boring: plan for the dates that are law. If the postponement is formalised, you'll simply be ready early.
Is Verifactu the same as e-invoicing?
No, and mixing the two up is common. They are separate obligations that Hacienda now wants to line up.
Verifactu is about how your software records invoices and, in VERI*FACTU mode, reports them to the Agencia Tributaria.
B2B e-invoicing is about sending invoices to other businesses as structured electronic files instead of PDFs. It comes from Ley 18/2022 ("Crea y Crece"), and is developed by Real Decreto 238/2026, published in the BOE on 31 March 2026. The deadlines in that decree run from the entry into force of the ministerial order that regulates the public e-invoicing solution. That order, Orden HAC/1028/2026, was published on 5 October 2026 and came into force on 6 October 2026. So:
- businesses and professionals whose turnover exceeded 8 million euros in the previous calendar year: twelve months later, which is 6 October 2027
- everyone else, including autónomos: twenty-four months later, which is 6 October 2028
Simplified invoices (tickets) are excluded unless they are facturas simplificadas cualificadas. For self-employed individuals under the threshold, the decree adds a further delay before they have to report the status of their invoices.
What happens if your software isn't compliant?
The Ley General Tributaria, article 201 bis, makes it a serious tax offence to have invoicing software that doesn't meet the requirements, when it should be certified and isn't or when it has been altered. The fine is a fixed 50,000 euros per tax year. For those who make and sell non-compliant software, it's 150,000 euros per year and per type of program.
Those amounts are why we take the dates seriously even while the calendar is being renegotiated.
What does it mean for your invoicing software?
In practice, three questions.
1. Is your program adapted? Ask your provider for their declaración responsable. Each software maker has to declare, for a specific product and version, that it meets the regulation. The declaration comes from the software maker, not from the tax agency, so it's the document to ask for. If your provider can't show one, that's your answer.
2. Which mode will you use? VERI*FACTU mode sends each invoice as you issue it. The Agencia Tributaria says that once you start sending, you stay in that mode until the end of the calendar year. Non-VERI*FACTU mode has more technical requirements for the software, and the Agencia Tributaria notes that software which can only work in that mode is not allowed. Decide with your gestor.
3. How do you correct a mistake? The point of the rules is that an issued invoice can't be edited or deleted. A mistake gets a corrective invoice in its own series, which Spanish invoicing rules already required. If your current habit is "open the PDF and fix it", that habit is what has to change.
- You know whether you're in scope: tax regime, territory, SII or not
- You know your date: 1 January 2027 for corporate tax, 1 July 2027 for everyone else, unless a new rule changes it
- Your software provider has given you its declaración responsable for the version you use
- You've chosen a mode with your gestor
- Your team corrects invoices with rectificativas, not by editing
- You've noted the separate B2B e-invoicing date: 6 October 2027 or 2028
Where Holded fits
We implement Holded as an official Solution Partner, so we're not neutral on software. Holded states that its invoicing is adapted to Verifactu, and in the setups we do the Verifactu status of each invoice sits beside the document with the QR on it. That covers the software. It doesn't decide your series, your mode or your date, and it doesn't replace your gestor's view of your situation. One caution: Holded's own Verifactu page already gives October 2028 as the date for businesses and autónomos. That is the announced postponement, not the law in force.
If you remember one thing
- The dates in force are 1 January 2027 (corporate tax) and 1 July 2027 (everyone else).
- October 2028 has been announced, not published. Plan for the law, not the press release.
- E-invoicing between businesses is a separate obligation, with its own dates.
If you're changing invoicing software anyway, it's a good moment to set it up properly. Book the call and we'll look at what you use now and what moving would involve.
Sources
- Real Decreto 1007/2023, Reglamento de sistemas informáticos de facturación, consolidated text (BOE)
- Real Decreto-ley 15/2025, de 2 de diciembre (BOE-A-2025-24446)
- Orden HAC/1177/2024, de 17 de octubre (BOE)
- Agencia Tributaria: note on the extension of the adaptation period
- Agencia Tributaria: who is obliged and which operations are included
- Agencia Tributaria: FAQ on VERI*FACTU systems
- Agencia Tributaria: FAQ on scope, including handwritten invoices, word processors and spreadsheets
- Agencia Tributaria: FAQ on the declaración responsable
- Agencia Tributaria: FAQ on the QR code and the VERI*FACTU legend
- Agencia Tributaria: FAQ index, Sistemas Informáticos de Facturación
- Ministerio de Hacienda: nota informativa of 5 October 2026 (PDF)
- Real Decreto 238/2026, de 25 de marzo, B2B e-invoicing (BOE)
- Orden HAC/1028/2026, de 2 de octubre, public e-invoicing solution (BOE-A-2026-20587)
- Ley 58/2003 General Tributaria, art. 201 bis (BOE)
- Real Decreto 1619/2012, Reglamento de obligaciones de facturación (BOE)
Builds websites and the systems behind them for small businesses in Spain and the Netherlands. Writes down the things clients ask twice.
