Summary
- On 5 October 2026, the Spanish announced its intention to postpone the remaining deadlines under the VERI*FACTU/SIF invoicing-software regime until October 2028, seeking greater alignment with Spain’s B2B e-invoicing system. The Government announcement is a planned legislative change, meaning the currently enacted deadlines should not yet be treated as formally replaced. [hacienda.gob.es], [sede.agenc…ria.gob.es]
- The postponement would particularly affect businesses and professionals still facing implementation obligations under Royal Decree 1007/2023. The Ministry says that the fundamental SIF requirements concerning integrity, conservation, accessibility, legibility, traceability and inalterability will remain substantially equivalent. [hacienda.gob.es]
- The change does not postpone Spain’s separate B2B e-invoicing mandate. Following publication of Order HAC/1028/2026, B2B e-invoicing becomes mandatory on 6 October 2027 for businesses with turnover above €8 million and on 6 October 2028 for the remaining businesses and professionals within scope. [peppol.nu]
Spain moves towards convergence of VERI*FACTU and B2B e-invoicing
Spain is planning another important change to its digital invoicing timetable. On 5 October 2026, the announced that it intends to postpone the outstanding obligations arising from the invoicing-software regulation established by Royal Decree 1007/2023, commonly associated with VERI*FACTU, until October 2028. [hacienda.gob.es], [sede.agenc…ria.gob.es]
The stated objective is not simply to provide businesses with additional implementation time. Rather, the Ministry wants to achieve greater regulatory and technical convergence between the VERI*FACTU invoicing-software requirements and Spain’s new B2B electronic invoicing system. According to the Ministry, aligning the two implementation schedules should allow the outstanding VERI*FACTU obligations to coincide with the B2B e-invoicing obligation applicable to businesses and professionals whose annual turnover does not exceed €8 million. [hacienda.gob.es], [peppol.nu]
This distinction is important. Spain is dealing with two related but legally distinct digital invoicing regimes. VERI*FACTU/RRSIF primarily regulates the characteristics and integrity of the computer systems used to create invoices. The B2B e-invoicing mandate, developed under the Crea y Crece framework, concerns the electronic exchange of structured invoices between businesses and associated invoice-status information. [sede.agenc…ria.gob.es], [peppol.nu]
The postponement has not yet changed the law
Businesses should not yet treat October 2028 as the legally effective VERI*FACTU deadline.
The Ministry’s announcement is expressly framed as a planned modification of the deadlines. The (AEAT) also describes the development on its VERI*FACTU portal as a“forecast of extension of the deadline”, referring users to the Ministry’s 5 October communication. [sede.agenc…ria.gob.es], [hacienda.gob.es]
Consequently, the announcement represents a clear statement of Government policy and is highly relevant for implementation planning, but the postponement still needs to be translated into the corresponding legislative amendment before businesses can rely upon the new October 2028 date as law. [hacienda.gob.es]
That qualification is particularly important for businesses currently working toward the existing 1 January 2027 and 1 July 2027 implementation dates. Until the relevant legislation is amended, those dates should not simply be removed from compliance programmes.
What VERI*FACTU requires
The regime is more accurately described as the Spanish regulation governing Sistemas Informáticos de Facturación (SIF) rather than as a general e-invoicing obligation.
Royal Decree 1007/2023 establishes requirements intended to ensure that computerised invoicing systems protect the integrity, conservation, accessibility, legibility, traceability and inalterability of their invoice records. The Spanish tax authority explains that the regulation does not fundamentally alter businesses’ substantive invoicing obligations. Instead, it regulates how computerised invoicing systems must operate and the records they must create. [sede.agenc…ria.gob.es], [hacienda.gob.es]
This is also why references to “certified software” can be misleading. Compliance does not require prior AEAT accreditation of individual software products. Under the current rules, responsibility lies with the producer of the invoicing system, which must provide a responsible declaration confirming that the system complies with the applicable requirements. The declaration must relate to the relevant version of the software. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]
AEAT has additionally made its own free VERI*FACTU invoicing application available, aimed particularly at professionals, self-employed persons and smaller businesses that do not have their own invoicing software or wish to use a free alternative. [sede.agenc…ria.gob.es]
SII businesses are an important distinction
For larger Spanish businesses, the interaction with the existing Immediate Supply of Information (SII) VAT reporting regime remains important when determining VERI*FACTU applicability.
This is also one reason why VERI*FACTU and Spain’s B2B e-invoicing mandate should not be conflated. A business may fall outside particular RRSIF/SIF requirements because of the interaction with SII while nevertheless being required to exchange structured B2B electronic invoices under Spain’s new e-invoicing rules. The AEAT’s scope guidance expressly treats the SII status of taxpayers as relevant to determining the application of the RRSIF regime. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]
In practical terms, therefore, the proposed postponement is especially relevant for smaller businesses and self-employed professionals that use invoicing software and are not already operating through SII.
B2B e-invoicing continues on a separate timetable
While VERI*FACTU is heading towards postponement, Spain has simultaneously brought greater certainty to the separate B2B e-invoicing mandate.
Order HAC/1028/2026 was published on 5 October 2026 and entered into force on 6 October 2026. This triggered the implementation periods under Spain’s B2B e-invoicing framework. Businesses and professionals with turnover exceeding €8 million in the preceding calendar year are required to comply from 6 October 2027. The remaining businesses and professionals within scope follow from 6 October 2028. [peppol.nu], [dynatos.com]
The B2B system goes significantly beyond generating an electronic PDF. It establishes a structured e-invoicing environment incorporating the public solution operated by AEAT and private e-invoicing platforms. The framework supports structured formats based on the EN 16931 semantic model and also introduces communications concerning invoice status and payment. Where invoices are handled through private platforms rather than AEAT’s public solution, a faithful electronic copy in UBL must be transmitted to the public solution. [peppol.nu], [vatcalc.com]
Importantly, SII membership does not in itself remove the B2B e-invoicing obligation. The B2B mandate and the invoicing-software/SII landscape therefore need to be assessed separately for each taxpayer and invoice flow. [peppol.nu], [sede.agenc…ria.gob.es]
Why October 2028?
The policy logic behind the proposed postponement is becoming clearer.
Under the confirmed B2B timetable, smaller businesses and professionals within scope will transition to mandatory structured B2B invoicing on 6 October 2028. Moving their outstanding invoicing-software obligations to October 2028 potentially allows these taxpayers to deal with the ERP, invoicing-software and process changes through a more coordinated implementation programme rather than completing two substantial transformations at different points in time. [hacienda.gob.es], [peppol.nu]
The Ministry has gone further, indicating that once the timetable alignment has been approved, it intends to examine modifications designed to achieve greater convergence of the scope and technical aspects of the two regimes. Significantly from an EU VAT perspective, the Ministry expressly states that this future work will take into account the digital reporting requirements arising from VAT in the Digital Age (ViDA). [hacienda.gob.es]
At the same time, Spain is not signalling a retreat from transaction-level digital controls. The Ministry specifically says that the existing requirements concerning the integrity, conservation, accessibility, legibility, traceability and inalterability of records, together with the other technical guarantees of the system, are expected to remain in substantially equivalent form. [hacienda.gob.es]
What businesses should do now
The announcement should therefore be seen as additional implementation time rather than cancellation of VERI*FACTU.
Businesses potentially affected should keep the distinction between the three Spanish digital compliance layers clear: SII VAT reporting, the RRSIF/VERI*FACTU invoicing-software requirements, and the Crea y Crece B2B structured e-invoicing mandate. Their respective scopes are not identical, and participation in one regime does not automatically resolve obligations under another. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es], [peppol.nu]
For taxpayers currently preparing for the 2027 VERIFACTU dates, the immediate priority is to monitor the legislation implementing the announced postponement before formally resetting implementation deadlines. At the same time, businesses subject to the first wave of B2B e-invoicing should continue preparing for 6 October 2027, as that date follows from the now-published B2B framework and has not been postponed by the VERIFACTU announcement. [hacienda.gob.es], [peppol.nu]
For smaller businesses, the eventual alignment could provide an opportunity to build one coordinated October 2028 transformation programme covering compliant invoicing software and structured B2B e-invoicing. That appears to be precisely the convergence Spain’s Ministry of Finance is now seeking. [hacienda.gob.es]
External sources
- Revo
- Spanish Ministry of Finance – Communication of 5 October 2026 on the planned extension of the VERI*FACTU/SIF deadlines
- Spanish Tax Agency (AEAT) – Billing Computer Systems (SIF) and VERI*FACTU
- Spanish Tax Agency (AEAT) – Scope and general requirements of the SIF/VERI*FACTU rules
- Spanish Tax Agency (AEAT) – Certification of invoicing systems and responsible declaration
- Spain B2B e-invoicing – Order HAC/1028/2026 and confirmed 2027/2028 implementation dates
Click on the logo to visit the website
Other articles
- Spain’s Ministry of Finance has proposed delaying Verifactu to October 2028, so it would begin at the same time as mandatory B2B e-invoicing for companies with turnover up to €8 million.
- Verifactu requires businesses and self-employed professionals to use certified, tamper-evident invoicing software that records and may transmit billing data to the Spanish Tax Agency (AEAT).
- Under the current rules, Verifactu would start on 1 January 2027 for Corporate Income Tax taxpayers and on 1 July 2027 for Spanish branches/permanent establishments of non-resident companies subject to Non-Residents Income Tax.
- The postponement is not yet legally effective; current deadlines remain in force until an amending rule is published in the BOE.
Source: meridianglobalservices.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
Latest Posts in "Spain"
- Spain mandates phased B2B eInvoicing under Crea y Crece Law
- Spain: Supreme Court allows VAT balance verification from prescribed periods
- Spain: New Rules for Computerised Invoicing Systems and VERIFACTU
- Spain VAT Deductibility and Article 96 Exclusions After Randstad España and Heineken
- AEAT Publishes Technical Documentation and Connection Examples for the Public Electronic Invoicing Solution (SPFE)
