Verifactu postponed to 2028: dates and legal status

What the Ministry of Finance has announced

On 5 October 2026 the Ministry of Finance’s press office published an information note entitled “Previsión de modificación de los plazos de aplicación de las obligaciones pendientes” (planned change to the application deadlines of the outstanding obligations) of Real Decreto 1007/2023, the regulation governing computerised invoicing systems and Verifactu.

According to the note, the Ministry considers it advisable to align the timetables for Verifactu and for mandatory business-to-business e-invoicing and, therefore, to postpone the outstanding obligations of Real Decreto 1007/2023 until October 2028, so that they coincide with the e-invoicing obligation for businesses and professionals with an annual turnover of up to 8 million euros.

The note adds two important points: that a further amendment will later be made to bring the scope of both systems into line, and that the requirements for the integrity, preservation, accessibility, legibility, traceability and unalterability of records “will be maintained in substantially equivalent terms”.

The note does not say which legal instrument will make the change or on what exact date in October 2028.

What the law says today

The dates in force are those set by Real Decreto-ley 15/2025 of 2 December (BOE of 3 December 2025), which the Spanish Parliament (Congreso) ratified on 11 December 2025. That text rewrote the fourth final provision of Real Decreto 1007/2023:

Corporate Income Tax payers: their invoicing systems must be adapted before 1 January 2027.
All other obligated taxpayers (self-employed people taxed under IRPF, income-attribution entities, non-resident income tax (IRNR) payers with a permanent establishment): before 1 July 2027.

As of 20 October 2026, no law changing those dates has been published in the BOE. The Spanish Tax Agency itself, in its information note on the adaptation deadline (updated on 13 October 2026), still gives 2027 and presents the postponement to 2028 as a plan communicated by the Ministry.

The announcement and the law, side by side.
	What is in force	What has been announced
Document	Real Decreto-ley 15/2025 (BOE, 3/12/2025), ratified by Parliament	Information note from the Ministry of Finance (5/10/2026)
Legal status	A rule with the force of law, binding	Announcement of an intention; not binding in itself
Companies (Corporate Income Tax)	Before 1 January 2027	October 2028
Self-employed and other obligated taxpayers	Before 1 July 2027	October 2028

Deadlines by type of taxpayer

Software manufacturers

Producers of invoicing software had nine months from the entry into force of Orden HAC/1177/2024 (29 October 2024) to adapt their products, that is, until 29 July 2025. That deadline has not changed. Each producer certifies that its software complies through a statement of compliance (declaración responsable): the AEAT does not approve or certify software.

Companies

Legally, before 1 January 2027. If the announced postponement is approved, this would move to October 2028.

Self-employed people and professionals

Legally, before 1 July 2027. With the announced postponement, also October 2028.

Basque Country and Navarre

The regulation applies without prejudice to the regional “foral” systems. Anyone whose tax residence is in Álava, Bizkaia, Gipuzkoa or Navarre follows their own systems (TicketBAI and Batuz in the Basque Country).

Why October 2028: business-to-business e-invoicing

The date is no coincidence. On that same day, 5 October 2026, the BOE published Orden HAC/1028/2026, which regulates the public e-invoicing solution and came into force on the 6th. It starts the clock on the deadlines of Real Decreto 238/2026, the regulation on mandatory e-invoicing between businesses and professionals:

Twelve months later for those whose turnover exceeded 8 million euros in the previous year (around October 2027).
Twenty-four months later for everyone else (around October 2028).

The approximate dates are our own calculation from the order’s entry into force; the BOE does not state them as specific days. We explain this in our guide to mandatory B2B e-invoicing.

What to do now

Don’t take the new date for granted. Until it is published in the BOE, the 2027 timetable is the binding one.
Choose invoicing software that is ready now. Switching tools in a hurry, a few weeks before a deadline, is what causes the most mistakes.
Ask for the statement of compliance of the software you use. It is the document in which the manufacturer certifies that it complies with the regulation.
If you wish, start sending records to the AEAT voluntarily. Submission of records (VERI*FACTU mode) is already available. Bear in mind that once you start sending, you must stay with that option at least until the end of the calendar year.
Keep an eye on the BOE and the AEAT’s online portal. We will update this page when the law changing the dates is published.

zBilling generates the record for every invoice and receipt with its chained hash and QR code, and sends it to the AEAT with your digital certificate. You can test the connection in the Tax Agency’s test environment before going live. Find out more in what Verifactu is and how zBilling applies it.

What remains uncertain

The specific law that will make the change and the exact day in October 2028.
Whether the postponement will be the same for companies and the self-employed or will vary by size, as e-invoicing does.
What will change in the “convergence” of scope between Verifactu and e-invoicing that the note announces.

What the Ministry has said is that the technical requirements for records will remain substantially the same. Adapting today is not wasted effort.

Frequently asked questions

Is Verifactu no longer mandatory in 2027?

For now it is: Real Decreto-ley 15/2025 sets 1 January 2027 for companies and 1 July 2027 for everyone else. The postponement to October 2028 is a plan announced by the Ministry of Finance on 5 October 2026, which needs to be published in the BOE to take effect.

What happens if I don’t adapt in time?

Article 201 bis of the Ley General Tributaria punishes possessing invoicing systems that do not meet the requirements with a fixed fine of 50,000 euros per financial year, and those who manufacture or sell them with 150,000 euros per financial year and per type of software. Penalties apply once the obligation is enforceable.

Does the postponement change what my software has to do?

According to the Ministry’s note, not in essence: the requirements for the integrity, preservation, traceability and unalterability of records will be maintained in substantially equivalent terms.

Can I use Verifactu before it becomes mandatory?

Yes. Sending records to the AEAT is voluntary and already available. If you choose that mode, you must stay with it at least until the end of the calendar year in which you made the first submission.

Does it affect the Basque Country and Navarre?

Not directly. The Verifactu regulation applies without prejudice to the regional “foral” systems; the Basque Country uses TicketBAI.

Official sources

Information prepared from the official sources cited and reviewed on the date shown. It does not replace professional advice for your specific situation.

What is Verifactu?

How a verifiable invoice works, who it affects and how zBilling applies it.

Mandatory B2B e-invoicing

Deadlines, formats and how it differs from Verifactu.

Free AEAT app or invoicing software

What the Tax Agency’s app offers and when it is enough for you.

Tax calendar

Deadlines for modelos 303, 130, 111 and 115.