VeriFactu: when it binds you, and what is really postponed
The Spanish Treasury has moved this timetable three times. This is what is published in the official gazette today, kept apart from what has only been announced, with a link to each rule so you do not have to take our word for it.
The timetable, date by date
- In force29 July 2025Fabricantes de software de facturación· RD 1007/2023
- In force1 January 2027Empresas que tributan por el Impuesto sobre Sociedades· RD-ley 15/2025
- In force1 July 2027Autónomos y resto de obligados tributarios· RD-ley 15/2025
- Announced, unpublishedOctober 2028Empresas y autónomos que facturan menos de 8 M€· anuncio del Ministerio de Hacienda de 5 de octubre de 2026
A postponement has been announced but not yet published. Until it reaches the official gazette, the binding dates are the ones marked «In force».
Has it been postponed to 2028?
Announced yes, published no. On 5 October 2026 the Spanish Treasury put out a note saying it intended to move the remaining deadlines to October 2028, so they line up with mandatory e-invoicing. A ministry note is not a law.
Until a provision amending the fourth final provision of Royal Decree 1007/2023 appears in the official gazette, the 2027 dates are what binds you. That is what the consolidated text says today, and that is what to check before believing anyone.
Planning around the announced date instead of the published one is betting that a ministry note reaches the gazette before 2027. It may. It has not yet.
What it actually requires
VeriFactu does not require you to send your invoices to the tax agency. It requires the software you invoice with to sign every invoice and chain its hash to the previous one, so an issued invoice cannot be deleted or altered without it showing. Each invoice also carries a QR code, and the software keeps an issue record for every one of them.
There are two ways to comply. In «VeriFactu» mode the software sends each record to the tax agency as the invoice is issued. In «non-VeriFactu» mode it does not, but then the records must be signed and kept under stricter requirements. Both are legal; the first is the one that removes paperwork.
It does not force you to change software: it forces the software to comply. If yours adapts, there is nothing to buy. Ask your current provider in writing before signing anything with anyone.
VeriFactu and e-invoicing are not the same thing
They get mixed up daily and they are two separate rules, with two separate regulations and two separate timetables. VeriFactu is about how an invoice is issued: that it cannot be tampered with. Business-to-business e-invoicing is about the format it travels in: a structured file the other side's software reads by itself.
You can get each one wrong independently. Software can comply with VeriFactu and still email PDFs, which are not electronic invoices. And the other way round. The October 2028 announcement exists precisely to bring the two dates together for small businesses, which tells you even the Treasury knows running them separately was a mess.
A PDF by email is not an electronic invoice, however many QR codes it carries and however well it complies with VeriFactu. They are two duties to check separately.
What is worth doing now
Ask whoever provides your invoicing software, in writing, whether it will comply and by what date. If the answer is vague or never comes, that is an answer in itself. If your invoicing is a spreadsheet or a paper book, there is no provider to ask and the change needs planning with time, not in December 2026.
What is not worth doing is signing in a hurry over a date that may still move, or dropping it entirely because a postponement was announced. Both cost you: the first in money, the second in December.
The penalties, with the article in front
Half the sector writes «€50,000 fine for not having VeriFactu». Article 201 bis of the General Tax Act does not say that: it penalises holding a system that should be certified and is not, or a certified one that has been tampered with. These are the three figures and what each applies to.
- 150.000 €per financial year with sales and per type of program
Making, producing or selling software that allows issued invoices to be deleted or altered
- 1.000 €per system sold without it
Selling a system without the certificate, where the regulation requires one
- 50.000 €per financial year
Holding a system that should be certified and is not, or a certified one that has been tampered with
Sources
- RD 1007/2023, de 5 de diciembre (texto consolidado) (BOE-A-2023-24840)
- RD-ley 15/2025, de 2 de diciembre (BOE-A-2025-24446)
- Ley 58/2003, General Tributaria, art. 201 bis (texto consolidado) (BOE-A-2003-23186)
- Sede electrónica de la AEAT: sistemas informáticos de facturación (AEAT)
Consolidated text of RD 1007/2023, article 201 bis of the General Tax Act and the AEAT site, all read on 3 November 2026. If another site shows a different date, check it against the gazette link before believing it, whoever it comes from.
What people ask us
When does VeriFactu come into force?
For companies paying Spanish corporate income tax, before 1 January 2027. For the self-employed and all other taxpayers, before 1 July 2027. Those are the dates in the fourth final provision of Royal Decree 1007/2023 as consolidated. A postponement to October 2028 has been announced but not published.
Is VeriFactu compulsory?
Yes, but not for everyone at once and not in the way it is usually told. What is compulsory is that the system you invoice with complies with the regulation. Sending the records to the tax agency as you issue — VeriFactu mode proper — is voluntary: the alternative is keeping them signed under stricter requirements.
Are VeriFactu and e-invoicing the same thing?
No. VeriFactu governs how an invoice is issued so it cannot be tampered with. Business-to-business e-invoicing governs the format the invoice travels in to reach the customer. Two separate regulations with separate timetables, and you can breach one while complying with the other.
Who is exempt from VeriFactu?
Those already on the immediate supply of information regime (SII), those invoicing in the foral territories under their own system, and transactions with no duty to issue an invoice. Being on a simplified tax regime does not exempt you by itself: what matters is whether you have to issue invoices.
Will I be fined if I do not have VeriFactu by 1 January 2027?
The €50,000 per financial year penalty in article 201 bis of the General Tax Act punishes holding a system that should be certified and is not, or a certified one that has been tampered with. It is not an automatic fine for missing a date. That said, invoicing with a non-compliant system is precisely the situation the article describes.
Can I keep invoicing with Excel?
A spreadsheet cannot meet the regulation: it does not sign, it does not chain hashes and it lets you alter what has already been issued. Paper invoice books remain legal where paper invoices are allowed, but the moment you issue from a computer system, that system has to comply.
Want to know whether your software complies?
Tell us what you invoice with. We will tell you whether what you already have is enough, what to ask your provider, and what it means if they do not answer. If an update is all you need, we will say so.
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