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Electronic invoice 7 min read

Verifactu postponed to October 2028: what it is and what to do

Spain postpones Verifactu to October 2028 to match the e-invoicing deadline for SMEs and the self-employed. What it is, who it binds and what to do while the rule arrives.

Equipo Cesko DesignAuthor

Verifactu se aplaza a octubre de 2028: qué es y qué hacer

Verifactu is the Spanish Tax Agency's system that requires the software you invoice with to generate tamper-proof records of every invoice and, optionally, send them to the tax authorities on the spot. On 5 October 2026 the Ministry of Finance announced that it is postponing the pending Verifactu obligations until October 2028, the same date on which e-invoicing becomes mandatory for those invoicing under 8 million euros. It is the third change of calendar and, as of today, 21 October 2026, it has not yet been published in the Official State Gazette: the dates still written in the rule are those of 2027. We explain what it is exactly, who it affects and what is worth doing in this situation.

What Verifactu is, in plain language

Royal Decree 1007/2023 approved the Regulation on invoicing computer systems (SIF), developed by Order HAC/1177/2024 and amended by Royal Decree 254/2025. The idea is simple: invoicing software must not allow invoices to be deleted or manipulated. To that end it requires every invoice to generate an invoicing record with a digital fingerprint chained to the previous one, invoices to carry a QR code and the software to be certified by a manufacturer's responsible declaration. There are two modes:

  • VERI*FACTU: the software sends every record to the Tax Agency on the spot. In return, you do not have to keep anything and the invoice carries the legend "Invoice verifiable at the AEAT electronic office".
  • Non-VERI*FACTU: the software stores the electronically signed records and keeps them; the tax authorities may request them.

All the official information is on the AEAT page on invoicing computer systems.

Who it binds

Businesses and professionals who invoice with a software program: companies, the self-employed, permanent establishments of non-residents and entities under the income attribution regime. Those already under the Immediate Supply of Information (SII), which has its own channel, are excluded, and the regulation does not apply in the foral territories (Basque Country and Navarre), which have their own systems (TicketBAI). If you write invoices by hand or with a Word template without an "invoicing computer system", the rule technically does not reach you, but in practice almost nobody is in that situation.

It also binds software manufacturers, who must offer adapted products; that is why your invoicing program is warning you (or should be).

The new calendar: October 2028

What the Ministry announced

The Ministry of Finance information note of 5 October 2026, also listed on the AEAT website, states that it has been deemed appropriate to "postpone the pending obligations of Royal Decree 1007/2023, of 5 December, until October 2028, so that they coincide with mandatory e-invoicing for businesses and professionals whose annual turnover does not exceed 8 million euros". The stated reason is to seek "the greatest possible convergence", both legal and technical, between Verifactu and e-invoicing, and to prepare for the future European digital reporting requirements (ViDA).

Three things worth reading carefully in that note:

  • It covers every pending obligation: companies and the self-employed now share the same date, October 2028. The January and July 2027 steps disappear.
  • The technical requirements do not change: integrity, preservation, accessibility, legibility, traceability and tamper-proofing of records "will be maintained in substantially equivalent terms". In other words, the software you will need is the same; you simply have more time.
  • It is a forecast, not yet a rule. The postponement needs a royal decree-law or a law published in the Official Gazette. Until that happens, the 2027 calendar is what is legally in force.

What the Official Gazette says in the meantime

Royal Decree-Law 15/2025, of 2 December, postponed the original calendar by one year. According to the AEAT information note, systems should be adapted before 1 January 2027 (corporate income tax payers) and before 1 July 2027 (self-employed under personal income tax, entities under income attribution and non-residents with a permanent establishment). These are the dates that October 2028 will replace once the rule is approved; until then there is a testing period in which you can send records in VERI*FACTU mode and, if it does not convince you, stop. Note that anyone who has already started submitting records cannot leave that mode until the end of the calendar year.

There was already a previous postponement that was announced months before it was approved, so this one will most likely reach the Gazette too. But it is worth looking at the calendar with that caution, especially if your invoicing software does not yet comply with the regulation.

What to do now (without paying twice)

  1. Do not postpone the software decision. Both Verifactu and B2B e-invoicing require updating or changing your invoicing program. Choose one that complies with both and do it only once.
  2. Ask your provider for the responsible declaration that their system complies with the regulation, and ask which mode they offer.
  3. Try VERI*FACTU mode during the testing period with a few invoices. It is reversible and takes away the fear.
  4. Review your invoicing circuit. Who issues, from which devices, how errors are corrected. With Verifactu an invoice is not deleted: it is cancelled or corrected with another one, and that changes habits.
  5. The postponement gives you time, not less work. In October 2028 you will have to comply with Verifactu and e-invoicing at the same time: better to arrive with software already running smoothly than to change everything in the last quarter.

Penalties

The General Tax Law (article 201 bis, introduced by Law 11/2021) classifies using or holding invoicing systems that do not comply with the regulation as an infringement, with fines of 50,000 euros per tax year for the user, and up to 150,000 euros per tax year and type of system for those who manufacture or sell them. The penalty regime has not been touched by the postponement. It is not the main reason to adapt, but it is worth knowing.

We have been accompanying SMEs and the self-employed with electronic invoicing and this transition for a while; most doubts are resolved in a half-hour conversation.

Frequently asked questions

Is Verifactu the same as mandatory e-invoicing?

No. Verifactu regulates how the software must work (tamper-proof records, QR, sending to the tax authorities). B2B e-invoicing (the Crea y Crece Law) regulates the format and exchange of invoices between businesses. They are two separate obligations that will coexist and that your software should meet at the same time.

Has Verifactu been postponed to 2028?

Yes: on 5 October 2026 the Ministry of Finance announced the postponement of all pending obligations until October 2028, for companies and the self-employed alike. As of 21 October 2026 the amendment has still to be published in the Official Gazette; until then, 1 January and 1 July 2027 formally remain in force.

When exactly in 2028 does it start?

The note says "October 2028" without a specific day. Mandatory e-invoicing for those invoicing under 8 million starts on 6 October 2028, and the declared intention is to make both dates coincide. The exact day will be set by the rule that is published.

Do I have to send invoices to the tax authorities in real time?

Only if you choose VERI*FACTU mode. The other mode keeps the signed records in your system without sending them, although the tax authorities may request them.

If you want to review your invoicing in good time and without surprises, tell us about your project and we will tell you what you need.

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