Verifactu pushed back to 2028: what's settled, what's missing and what to do meanwhile

What was announced, and what wasn't

On 5 October the Ministry of Finance published an information note saying it plans to postpone the Verifactu obligations that don't apply yet to October 2028, so they coincide with mandatory e-invoicing for businesses invoicing up to 8 million euros. We covered it alongside the e-invoicing calendar in Spain's e-invoicing mandate: 2027–2028 dates and Verifactu.

As of 23 October 2026, the change still hasn't been published. The consolidated text of Royal Decree 1007/2023 in the BOE still shows Royal Decree-law 15/2025 as its latest amendment, with the 2027 dates.

In the days since, three things have become clear that change how the news should be read:

• It isn't a regulation. It's a press note. The Verifactu dates are set in Royal Decree 1007/2023, and they only change when another regulation amending it is published in the BOE.
• The safeguards stay. The note says the integrity, retention, accessibility, legibility, traceability and immutability safeguards for the records will remain "substantially equivalent".
• A second amendment will follow. Once the calendars are aligned, the Ministry wants to bring Verifactu's scope and some technical aspects in line with the future EU digital reporting requirements (ViDA).

What's settled and what isn't

Why it matters that it's not in the BOE

Until the regulation is published, a company must invoice with Verifactu-ready software from 1 January 2027, less than three months away. The regulation will most likely arrive before then, but past experience suggests not taking it for granted too early: this is the third time the date has moved, and the last change was approved with barely a month to spare before the deadline it postponed.

The question about businesses above 8 million

The note ties the new date to e-invoicing for businesses invoicing up to 8 million, and some guides ask whether larger companies would have a different date. In practice very few are affected: a business with turnover above 6 million is a large company for VAT purposes, files through the SII (Immediate Supply of Information), and SII filers are outside Verifactu. Verifactu doesn't apply in the Basque Country or Navarre either, which have their own rules (TicketBAI in the Basque Country).

Relief and distrust

Reactions have gone two ways. The tax advisers' association AEDAF welcomed it: it had long asked for Verifactu and e-invoicing to arrive together so businesses only adapt once. UPTA, on the other hand, criticised it because it "penalises those who did their homework" and prolongs legal uncertainty.

Both views are partly right. But anyone who has already adapted hasn't lost anything: if the safeguards stay as the note says, their software remains valid. At most it will need the update the second amendment brings, and their vendor would have to ship that anyway.

What to do meanwhile if you run an SME

1. Don't stop the software switch. Pick software that covers both obligations: Verifactu and structured e-invoicing (EN 16931 standard and a connection to the Tax Agency's public solution or a private platform). The postponement lets you migrate once instead of twice.
2. If you're a company, have a plan for 1 January. Until the BOE publishes the change, confirm with your vendor that you can switch on Verifactu mode in time if needed.
3. If you've already adapted, carry on. Your software will remain valid, and if you already send your records to the Tax Agency in Verifactu mode, there's no reason to stop.
4. Use the extra time for what doesn't depend on the software: complete customer and supplier data, and an invoice reception process that doesn't rely on manual typing.

What to do if you run an accounting firm

The risk for a firm is that clients only hear "postponed to 2028" and shelve everything, including e-invoicing, which hasn't moved. It's worth:

• Sending a precise message. "The 2028 date is announced, not approved; the software you choose has to cover both Verifactu and e-invoicing."
• Segmenting clients. SII filers (outside Verifactu, but with e-invoicing from October 2027), companies (1 January 2027 unless the rule changes) and the self-employed and everyone else (1 July 2027).
• Preparing two communications. One for when the change is published in the BOE and another in case it still hasn't appeared by December.
• Keeping the software census up to date. Which program each client uses and whether it covers both obligations. It's the same census needed for e-invoicing.

This is repetitive, deadline-driven work, which is exactly what automates best. A digital employee can send each client the message for their group, collect which software they use, remind them of what's pending and give the firm a dashboard showing who's ready. When the regulation is published, the message is changed once and reaches everyone. The other processes worth automating are in automation for accounting firms.

What to watch in the coming weeks

• The regulation in the BOE amending Royal Decree 1007/2023, and the exact day in October 2028.
• The Tax Agency website, which should update its calendar and FAQs once it's published.
• The second amendment, the one converging with ViDA. It may change which records the software has to generate and send, so it's worth reading the draft as soon as it goes to public consultation.

We'll update this article when the regulation is published. In the meantime, always check the current calendar in the BOE and on the Tax Agency's website.