Mandatory e-invoicing and Verifactu in 2028: what changes for Spanish businesses and accounting firms

What happened this week

Two pieces of news in two days that change the calendar of every Spanish business and accounting firm:

• 5 October 2026. The Official State Gazette (BOE) publishes Order HAC/1028/2026, which regulates the Tax Agency's public e-invoicing solution. The same day, the Ministry of Finance announces that Verifactu is moving to October 2028 to coincide with mandatory e-invoicing.
• 6 October 2026. The Order comes into force and, with it, the countdown starts for mandatory e-invoicing between businesses and professionals under Royal Decree 238/2026.

Until now, e-invoicing was "something that would come". From today it has a date.

The calendar

Before the announcement, Verifactu was due from 1 January 2027 for companies and from 1 July 2027 for everyone else, under Royal Decree-law 15/2025. The plan now is for both systems to arrive together and converge technically.

What changes in practice

The invoice stops being a PDF

Between businesses and professionals, an invoice will have to be a structured file following the European EN 16931 standard, in one of these syntaxes: UBL, CII, EDIFACT or Facturae. It can be exchanged through the Tax Agency's public solution or a private platform, which then sends a copy to the public solution.

A PDF sent by email will not, on its own, be a valid invoice between businesses covered by the obligation. Invoices to consumers are outside it.

You have to report acceptance and payment

This is the change you'll notice most day to day. Whoever receives an invoice will have to report:

• Its commercial acceptance or rejection, with the date.
• Its full effective payment, with the payment date.

And must do so within four working days. The goal is to measure real late payment, so payment-term information will no longer depend on what each company declares.

The Tax Agency will see invoices almost in real time

With e-invoicing and Verifactu running together, the Tax Agency will hold a copy of every B2B invoice and its status. Mismatches between what's invoiced, declared and collected will be easier to spot.

What it means for a business

Two years sounds like a lot, but there are three things to do and none of them takes a week:

1. Check your invoicing software. Can it send and receive structured invoices and connect to the public solution or a platform? If not, it needs replacing or extending.
2. Clean up client and supplier data. Correct tax IDs, addresses and payment terms, because a structured file doesn't accept incomplete data.
3. Prepare reception. Someone, or something, will have to check every invoice received, accept or reject it and report payment on time.

What it means for an accounting firm

For an accounting or tax advisory firm the impact is double: its own work changes and it has to guide all its clients through it.

• Client census. Knowing which clients are above 8 million (October 2027) and which aren't (October 2028), and which software each one invoices with.
• A long communication campaign. Telling each client their date, what they need to change and what the firm needs from them, and reminding them until they're ready.
• Structured reception. Invoices will arrive as data, not images. Reading gets simpler, but there will still be receipts, invoices from suppliers outside the obligation and transition periods.
• Payment statuses. Acceptance and payment statuses will have to match what bank reconciliation says. It's a new source of mismatches.

What to automate now

The calendar leaves room to do it properly, and these automations save hours from the first month, e-invoicing or not:

• Reception and reading of invoices from every channel, with checks (tax ID, totals, duplicates) before recording. When structured files arrive, the same workflow reads them without OCR. We explain it in invoice automation software for accounting firms.
• Bank reconciliation matching receipts and payments with invoices. It will be the basis for reporting payment status without doing it by hand.
• Client communication by deadline group. A digital employee can notify each client according to their date, find out which software they use, chase what's pending and give the firm a board showing who's ready and who isn't.
• Master data review. Spotting clients and suppliers with incomplete tax IDs or addresses before a structured invoice is rejected for it.

Where to start

Take the census: how many invoices you issue and receive, with which software and through which channels. That shows what you need to change and what to automate first. If you run an accounting firm, the other processes that can be automated are in automating an accounting firm and automation for accounting firms.

The regulations cited may change: always check the current calendar in the BOE and on the Tax Agency's website.