Spain's mandatory e-invoicing dates remain unconfirmed

E-invoicing: Spanish tax authority targets freelancers in 2026

The timeline is pressing, yet nothing has been published in the BOE (Official State Gazette). By July 29, 2025, software manufacturers must have their programs adapted to anti-fraud regulations; from then on, according to a participant claiming attendance at an AEAT meeting, companies would be obligated by January 1, 2026, and freelancers by July 1, 2026. These dates circulate among those who deal daily with the Tax Agency, but as of today, they lack official publication. That is the first trap: preparation is demanded for a rule that is not yet finalized.

The second trap is more uncomfortable. According to the same account, the AEAT does not certify anything. Responsibility for program compliance falls on the manufacturer and the taxpayer. Those who continue invoicing via Excel sheets, homemade templates, or software made by acquaintances place themselves outside the law unknowingly, some participants argue. The invoice ceases to be a document between two parties: it becomes a record traceable by the tax authorities.

What exactly changes with Verifactu

The system rolls out in two modes. In the connected mode, each invoice is communicated to the AEAT in real time and carries a QR code allowing validity checks. In non-connected mode, the software meets technical requirements but does not send data instantly. In both cases, the program must prevent fraudulent practices and keep a trail of every operation: if an invoice is modified, the previous version remains recorded.

There is one exception worth highlighting: according to the debate, companies invoicing over 6 million euros are exempt from the obligation. No QR codes will appear in large retail chains. Control focuses once again on small commerce and self-employed professionals, who have the least structure to absorb these costs.

Adaptation costs and who pays

Budgets handled by consultancies for updating software start above 700 euros, according to one participant, even before manufacturers have operational versions. Maintenance costs have doubled in many firms, which now charge for it as an additional service. Agencies call providers to extract Form 347 models, invoices, and quarterly reports; they can no longer cope explaining the same things repeatedly.

Meanwhile, business moves. As discussed in the thread, investment funds have entered the management software sector: 650 million into Odoo by a US fund, and acquisitions of Software del Sol, Aplifisa, Distrito-K, and Acumbamail by an Italian fund. Circulating estimates speak of a 4 billion euro increase in service billing derived from these changes. Legal obligation is also a market.

What about freelancers who invoice manually?

Until the obligation comes into force, freelancers may continue issuing carbon-copy invoices, numbered and with all required data, as argued in the debate. What they cannot do is use non-compliant software: if the program is not adapted, the invoice is illegal even if the paper is perfect. The boundary between artisanal and prohibited is marked by the tool, not the format.

Control of card payments exceeding 25,000 euros annually completes the picture, according to statements in the thread. Some have already started paying in cash to avoid inflating that record. Mandatory e-invoicing, treasury control, and European ViDA projects point in the same direction: less room for informality.

The unanswered question concerns freelancers who outsource invoicing and receive it quarterly. If the issuer is a third party, who is responsible for the QR code, real-time transmission, and version history? The regulation, to date, does not clarify this.