Verifactu has been postponed until 2027: 2026 is the year to adapt your invoicing – slowly but surely
Following months of uncertainty and conflicting messages, the timetable for Verifactu — the verifiable invoicing system introduced by the Tax Agency in accordance with the Anti-Fraud Act (Act 11/2021) and Royal Decree 1007/2023 — has been set by Royal Decree-Law 15/2025 of 2 December, which has now been ratified by the Congress of Deputies. The extension is therefore final, and 2026 has been designated as a year of transition and voluntary adaptation.
The current timetable
- 1 January 2027: mandatory for corporation tax payers using computerised invoicing systems.
- 1 July 2027: mandatory for self-employed individuals (personal income tax), entities subject to income attribution and all other taxpayers.
- From 2025 and throughout 2026: voluntary period. You can start submitting records to the AEAT using the Verifactu method to test the system, with some flexibility to revert to previous methods until the date the system becomes mandatory.
Be wary of outdated information that is still circulating: the dates of 1 January and 1 July 2026 that were published previously are no longer valid.
Who is affected (and who is not)
The obligation applies to business owners, professionals and organisations that issue invoices via a computerised invoicing system (SIF), even if this applies only to part of their business. Taxpayers covered by the Immediate Information Supply (SII) scheme, who already submit their records in near real time, are exempt, as are autonomous communities with their own systems (such as TicketBAI in the Basque Country, which operates on its own timetable and is not affected by this postponement).
What the system requires
The invoicing software must guarantee the integrity, preservation, traceability and immutability of the records: each invoice generates a cryptographically chained, sealed record which, where applicable, includes a QR code allowing the recipient to verify it. Once issued, the invoice cannot be modified: any correction requires a corrective invoice. The automatic submission of records to the AEAT (the ‘Verifactu’ method in the strict sense) is optional, but it simplifies the technical requirements and enhances legal certainty.
Verifactu is not the mandatory electronic invoice
It is important not to confuse two distinct obligations. Verifactu regulates how the invoicing software must operate. Mandatory electronic invoicing between businesses (B2B), provided for in Law 18/2022 ‘Crea y Crece’, regulates the format and exchange of invoices to combat late payment, and is currently still awaiting regulatory development, with no definitive date for its entry into force. These are separate timetables and requirements, although they are expected to converge in practice.
Penalties: the risk of doing nothing
The possession or use of uncertified invoicing software — so-called ‘dual-use software’ — may result in penalties of up to 50,000 euros per financial year (Article 201 bis of the General Tax Law). The deferral does not suspend this liability regime: it simply allows more time to comply correctly.
Our recommendation for 2026
- Check with your software provider whether your programme, ERP or POS system will be adapted, by when and at what cost; if you do not receive a clear answer, consider switching to a different solution during 2026.
- If you issue invoices using Excel, Word or templates, plan your migration: these systems will not meet the requirements when the obligation comes into force.
- Consider voluntarily opting into the Verifactu scheme during 2026 to test the system without the threat of penalties.
- Review your internal invoicing processes (invoice series, corrective invoices, receipts) and train your administrative team in good time.
Do you have any queries about whether your company or business is subject to this requirement, or about how to plan for compliance?
At SF Abogados, we provide personalised advice. Contact us at www.sfabogados.com or call us, and we will assess your case.
Information note prepared by SF Abogados on 2 July 2026 based on Royal Decree 1007/2023, Order HAC/1177/2024 and Royal Decree-Law 15/2025 (BOE 3 December 2025), ratified by the Congress of Deputies. This content is for information purposes only and does not constitute tax advice on a specific case.
