Spain delays Verifactu to 2026 and 2027, but compliance costs keep rising
Spain's Council of Ministers postpones Verifactu to 2026 and 2027, but the cost of adapting software, computers and accounting services still falls on the self-employed and businesses.
English · Original discussion in Spanish · Published
Verifactu is delayed to 2026 and 2027, but the cost remains
The Spanish Council of Ministers approved a Royal Decree amending the invoicing systems Regulation and shifting the timeline: corporate income tax payers will have until 1 January 2026 to comply, and all other taxpayers until 1 July 2026. The original deadline was 1 July 2025. Software manufacturers and distributors will have nine months from the entry into force of Order HAC/1177/2024 to offer compliant products, the same period that applies to multi-year maintenance contracts signed earlier.
The stated goal is the fight against tax fraud and dual-use software. In practice, the delay does not remove the obligation: it defers it. And that is where the problem begins for those who invoice little.
What Verifactu requires, and what is not the same thing
It is worth separating concepts that are often confused. One thing is the electronic invoice, another is the Verifactu system, and another is the QR code on receipts. They are not the same rule nor the same timeline. Mandatory e-invoicing for the self-employed and businesses with turnover below 8,000,000 euros appears linked to Order HAC/1028/2026, according to the communications tax professionals are working from.
Regulation 1007/2023 establishes two routes for taxpayers using computerised invoicing systems: a system that meets the requirements of the General Tax Law and the Regulation itself, or joining the VAT Immediate Supply of Information scheme (SII). Within the first option, some distinguish between non-connected Verifactu —updating the software to a compliant one, with a manufacturer's certificate confirming it meets the requirements— and connected Verifactu, which sends data in near real time and prints a verification QR code.
The AEAT (Spanish tax agency) does not certify the software. The responsibility for having a compliant system falls on the manufacturer, the distributor and the customer. That detail, which sounds like fine print, is what turns compliance into a real financial risk.
How much compliance costs: the figures being discussed
For a shop that issues simplified invoices and only a few full invoices a year —17 in one specific case— the options on the table include adding the e-invoicing module to the management software, at a cost of 2,000 euros plus VAT; outsourcing each invoice to an accounting firm, which may charge 10 euros for a 40-euro invoice; or using the public Tax Agency app once available.
On top of that come the Verifactu module, e-invoicing and the V28 beacon. The bill keeps growing. There are solutions at 20 to 30 euros a month that pass the burden on to a third party, an option some consider the least bad.
The penalties under Law 11/2021 have been in force since July 2021 and are retroactive for the 2021-2026 tax years: 50,000 euros per year for users of non-certified software allowing double bookkeeping, and 150,000 euros for manufacturers. The timeline delay does not touch those figures.
The technical problem: new programs, old machines
Compliance is not always a software update. New or updated programs often require new machines. Anyone with an old computer may find that the Verifactu module will not run, the QR code is not generated or the e-invoice does not integrate. The cost stops being a licence and becomes a computer.
Some argue that programming this is not rocket science. A bespoke program for a type of business already sends the data, generates the QR and handles corrective invoices instead of voiding an invoice and issuing a new one. Registration in the Verifactu test system is done with one's own certificate in the test environment, nothing more. The debate is whether that is enough to comply, or whether certification and liability for every licence sold are a different matter.
The timeline keeps shifting
The dates are not final. The Forum of Tax Professional Associations and Bodies relayed an expectation of a deadline change: Verifactu's entry into force would move to 6 October 2028, coinciding with the date published in Order HAC/1028/2026 for mandatory e-invoicing. That expectation coexists with the calendar approved by the Council of Ministers and with the original 2025 date.
The overlap between e-invoicing and Verifactu is no coincidence. The more one is delayed, the closer it gets to the other. And the business of adapting software to regulations that keep changing dates is, in itself, a business.
The delay eases the 2025 calendar. It does not ease the bill for those who have to change software, computer or accountant. The question is no longer when it takes effect, but how much it will cost to be ready in time.
The Spanish Council of Ministers approved a Royal Decree amending the invoicing systems Regulation and shifting the timeline: corporate income tax payers will have until 1 January 2026 to comply, and all other taxpayers until 1 July 2026. The original deadline was 1 July 2025. Software manufacturers and distributors will have nine months from the entry into force of Order HAC/1177/2024 to offer compliant products, the same period that applies to multi-year maintenance contracts signed earlier.
The stated goal is the fight against tax fraud and dual-use software. In practice, the delay does not remove the obligation: it defers it. And that is where the problem begins for those who invoice little.
What Verifactu requires, and what is not the same thing
It is worth separating concepts that are often confused. One thing is the electronic invoice, another is the Verifactu system, and another is the QR code on receipts. They are not the same rule nor the same timeline. Mandatory e-invoicing for the self-employed and businesses with turnover below 8,000,000 euros appears linked to Order HAC/1028/2026, according to the communications tax professionals are working from.
Regulation 1007/2023 establishes two routes for taxpayers using computerised invoicing systems: a system that meets the requirements of the General Tax Law and the Regulation itself, or joining the VAT Immediate Supply of Information scheme (SII). Within the first option, some distinguish between non-connected Verifactu —updating the software to a compliant one, with a manufacturer's certificate confirming it meets the requirements— and connected Verifactu, which sends data in near real time and prints a verification QR code.
The AEAT (Spanish tax agency) does not certify the software. The responsibility for having a compliant system falls on the manufacturer, the distributor and the customer. That detail, which sounds like fine print, is what turns compliance into a real financial risk.
How much compliance costs: the figures being discussed
For a shop that issues simplified invoices and only a few full invoices a year —17 in one specific case— the options on the table include adding the e-invoicing module to the management software, at a cost of 2,000 euros plus VAT; outsourcing each invoice to an accounting firm, which may charge 10 euros for a 40-euro invoice; or using the public Tax Agency app once available.
On top of that come the Verifactu module, e-invoicing and the V28 beacon. The bill keeps growing. There are solutions at 20 to 30 euros a month that pass the burden on to a third party, an option some consider the least bad.
The penalties under Law 11/2021 have been in force since July 2021 and are retroactive for the 2021-2026 tax years: 50,000 euros per year for users of non-certified software allowing double bookkeeping, and 150,000 euros for manufacturers. The timeline delay does not touch those figures.
The technical problem: new programs, old machines
Compliance is not always a software update. New or updated programs often require new machines. Anyone with an old computer may find that the Verifactu module will not run, the QR code is not generated or the e-invoice does not integrate. The cost stops being a licence and becomes a computer.
Some argue that programming this is not rocket science. A bespoke program for a type of business already sends the data, generates the QR and handles corrective invoices instead of voiding an invoice and issuing a new one. Registration in the Verifactu test system is done with one's own certificate in the test environment, nothing more. The debate is whether that is enough to comply, or whether certification and liability for every licence sold are a different matter.
The timeline keeps shifting
The dates are not final. The Forum of Tax Professional Associations and Bodies relayed an expectation of a deadline change: Verifactu's entry into force would move to 6 October 2028, coinciding with the date published in Order HAC/1028/2026 for mandatory e-invoicing. That expectation coexists with the calendar approved by the Council of Ministers and with the original 2025 date.
The overlap between e-invoicing and Verifactu is no coincidence. The more one is delayed, the closer it gets to the other. And the business of adapting software to regulations that keep changing dates is, in itself, a business.
The delay eases the 2025 calendar. It does not ease the bill for those who have to change software, computer or accountant. The question is no longer when it takes effect, but how much it will cost to be ready in time.
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Summary of a discussion on Burbuja.info - Foro de economía, actualidad y política., translated from Spanish and reviewed before publication. Read the full discussion (22 replies).
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