- Hacienda announced on 5 October that it plans to postpone Verifactu’s pending obligations to October 2028.
- It is not yet a rule: until it is published in the gazette, 1 January 2027 (corporate taxpayers) and 1 July 2027 (the rest) remain in force.
- The reason is to align it with the mandatory e-invoicing between businesses, regulated by an order published the same day.
On Monday 5 October 2026 the Ministry of Finance published an information note titled “Forecast of a change to the application deadlines”, announcing that it plans to postpone to October 2028 the pending obligations of Royal Decree 1007/2023, the regulation on invoicing software systems known as Verifactu. The stated aim is for its application to coincide with that of mandatory e-invoicing for businesses and professionals with annual turnover of up to €8 million, so that small businesses and the self-employed make one system change instead of two.
It is a forecast, not a rule. To give it effect, a new amendment to the fourth final provision of Royal Decree 1007/2023 will be needed, and it has not yet appeared in the gazette. In the meantime, the legally enforceable deadlines, set by Royal Decree-Law 15/2025 of 2 December, remain 1 January 2027 for corporate income tax taxpayers and 1 July 2027 for everyone else.
What stays
The note states that the requirements of integrity, retention, accessibility, legibility, traceability and inalterability of invoicing records will remain substantially equivalent to those of the current regulation. The postponement therefore concerns the timetable, not the substance: the invoicing software must still meet the technical requirements, including the QR code and, where applicable, the “verifiable invoice” legend.
Systems can work in two modes: Verifactu, which sends invoicing records automatically to the Tax Agency, and non-Verifactu, which does not send them but must keep them unaltered; the choice is voluntary for the taxpayer. After aligning the timetables, Hacienda foresees another amendment to bring the scope and certain technical aspects closer to the future European VAT digitalisation requirements, known as ViDA.
E-invoicing between businesses
On the same 5 October the gazette published Order HAC/1028/2026, which regulates the Tax Agency’s public e-invoicing solution, in application of Royal Decree 238/2026 of 25 March, which develops mandatory e-invoicing between businesses and professionals. The order entered into force on 6 October and the count of the application deadlines starts running with it.
According to the Tax Agency, those deadlines are 6 October 2027 for companies with turnover above €8 million; 6 October 2028 for other businesses and professionals, to which is added, for legal entities, the duty to report on invoice status and payments; and 6 October 2029 for individuals and income-attribution entities, as regards that reporting. Those who do not use the public solution must send it a faithful electronic copy of each invoice in UBL format when issuing it.
What to do
Until the rule is published, the prudent course is to treat the 2027 deadlines as in force. Anyone who has already adapted their invoicing software can expect their effort to remain useful, because the substantive requirements would stay. For companies that have not started, the planned postponement gives room, but it should not be confused with an exemption. It is useful to ask the software provider whether its product meets the regulation and what timetable it foresees.
It is also worth coordinating the two projects, verifiable invoicing and e-invoicing. If the timetable is unified in October 2028 for small businesses, it will make sense to choose a provider that covers both obligations. Consult your tax adviser on when each applies to you according to your turnover and legal form, and follow the gazette for the rule that changes the deadlines.
A longer timetable is a chance to do it once and do it well.
This article is general information. It is not legal, tax or investment advice, and it does not take anyone’s particular circumstances into account.
