Verifactu pushed back to 2028 and Spanish e-invoicing now has dates: what changes for your company

On 5 October 2026 two things happened on the same day in Spain. The Official State Gazette (BOE) published the order that sets mandatory business-to-business e-invoicing in motion, and the Ministry of Finance announced, in an information note, that it intends to postpone Verifactu to October 2028 so that both arrive together.

If your company invoices in Spain (a Spanish company, or the Spanish subsidiary or branch of a foreign group), this affects you.

The short answer: B2B e-invoicing now has firm dates, October 2027 if you invoice more than €8 million a year and October 2028 if you invoice less. The Verifactu postponement has been announced but is not yet in the BOE: until it is published, the legal dates are still 1 January 2027 for companies subject to corporate tax and 1 July 2027 for everyone else. Both obligations affect the same software, so the sensible thing is to prepare for them together.

What exactly happened

• E-invoicing. Order HAC/1028/2026 of 2 October regulates the Tax Agency's public e-invoicing solution. It was published in the BOE on 5 October and came into force on the 6th. It starts the clock set by Royal Decree 238/2026, the regulation on e-invoicing between businesses and professionals: 12 months for those invoicing more than €8 million a year and 24 months for everyone else.
• Verifactu. The Ministry's note announces that the outstanding obligations of Royal Decree 1007/2023, the Verifactu regulation, will be postponed to October 2028. It adds that a further amendment will follow to bring Verifactu closer to e-invoicing and to the new European VAT rules. A press note does not change the law: the postponement takes effect once the amendment to the regulation is published in the BOE.

The dates in one table

Two different obligations

They are often confused because both are about invoices and the Tax Agency, but they ask for different things.

• Verifactu is about the software you issue invoices with. Every invoice generates a record with a fingerprint that chains it to the previous one, it carries a QR code, and the software does not allow anything issued to be deleted or altered without a trace. In VERI*FACTU mode, the records are sent to the Tax Agency as they are created. The software maker has to sign a statement of compliance (declaración responsable).
• E-invoicing is about the document exchanged between the company that invoices and its customer. Between businesses, a PDF will no longer be valid: the invoice will have to use a structured format that software can read without interpreting anything (UBL, CII, EDIFACT or Facturae, under the European standard EN 16931), sent through a private platform or the Tax Agency's public solution. On top of that, the status of each invoice will have to be reported: whether it is accepted, whether it is rejected and when it is paid. The Government wants to use that data to measure late payment.

One detail simplifies things for many medium and large companies. Verifactu does not apply to companies that already keep their VAT books through Immediate Supply of Information (SII), which is mandatory for those invoicing more than €6 million a year. For almost every company above €8 million, the date that counts is the e-invoicing one, October 2027, and the Verifactu postponement changes nothing for them. Verifactu does not apply in the Basque Country and Navarre either, which have their own systems, such as TicketBAI.

Three reasons not to wait until 2028

1. Until it is in the BOE, the date is 1 January 2027. For a company, that is eleven weeks away. Invoicing software makers are adapting their products anyway.
2. E-invoicing does have a firm date, and the first wave arrives within a year. Smaller companies will feel it before 2028, because their large customers and suppliers will start sending them structured invoices from October 2027.
3. Both obligations touch the same software. Preparing for Verifactu now and for e-invoicing a year later means paying twice to review the ERP, the integrations and the processes.

Where the real work is

In most companies, invoices do not come from a single place. They come from the ERP, but also from the project or site management software, the point-of-sale system, the online shop, the CRM's quoting tool or a spreadsheet someone has maintained for years. And incoming invoices arrive by email, as PDFs, and someone types them in.

Verifactu and e-invoicing affect every one of those paths:

• Every place that issues invoices has to comply, or stop issuing them and pass the data to the software that does. The Tax Agency may treat a spreadsheet or a word processor used to produce invoices as an invoicing system: what counts is what the tool does, whatever it is called.
• Incoming invoices change shape. For a few years PDFs will coexist with structured invoices, which arrive with every field already separated and can be booked without typing. Taking advantage of that requires the ERP or accounting software to import them and match them against the purchase order and the delivery note.
• Payment status comes from treasury. To report when each invoice is paid, the bank data and the ERP data have to be connected. If bank reconciliation is done by hand today, this is the point that will take the most work.

All of this is integration: getting the software you already have to pass data to each other. Changing your management software is rarely necessary. If yours adapts (or its maker adapts it), it is enough to connect to it whatever runs outside it today, as we explain in detail in automating invoicing without changing software (in Spanish).

What to do in the coming weeks

1. List every place an invoice comes from, including spreadsheets and the credit notes that are made by hand.
2. Ask each software maker in writing whether they have the Verifactu statement of compliance, which structured formats they issue and receive, whether they connect to the Tax Agency's public solution or through which platform, how they report invoice status and how much each item costs. What a vendor can charge for opening its software to others is covered in connecting AI to your ERP or CRM.
3. Decide where you will receive structured invoices and how they will reach the ERP without being typed in.
4. Check how payment information reaches your system. If reconciliation is manual, it is the first process worth automating.
5. Put a date on each task using the calendar in the table, starting with the obligation that affects you first.

Frequently asked questions

Has Verifactu already been postponed to 2028?

It has been announced, not approved. The Ministry of Finance communicated it in an information note on 5 October 2026. Until the amendment to Royal Decree 1007/2023 is published in the BOE, the dates in force are 1 January 2027 for companies subject to corporate tax and 1 July 2027 for everyone else.

When does B2B e-invoicing become mandatory in Spain?

In October 2027 for those invoicing more than €8 million a year and in October 2028 for all other companies and self-employed professionals. The 12- and 24-month periods started on 6 October 2026, when Order HAC/1028/2026 came into force.

Will a PDF sent by email still be valid as an invoice?

Between businesses, from your date onwards, no: it will have to use a structured format such as UBL or Facturae. Consumers can still be given a PDF or a receipt.

Do I have to change my invoicing software?

Only if yours is not going to adapt. Ask the maker for the Verifactu statement of compliance and about e-invoicing formats. If it has them, the work lies in connecting to it the software that issues invoices outside it today.

What is the fine for using software that does not comply with Verifactu?

Article 201 bis of Spain's General Tax Law sets €50,000 per financial year for anyone holding non-compliant software, and €150,000 per year and type of software for whoever makes or sells it.

If you want to review how invoices go out of and come into your company today, tell us which software you use.

This article is informational and does not replace tax advice. Tecnea connects AI and automation to the management software companies already use, so we have a commercial interest in the topic. We cite the Ministry's note as reported by the Spanish financial press, and the exact e-invoicing dates from published analyses of Order HAC/1028/2026: check them in the BOE before making decisions.

Sources

1. Ministerio de Hacienda, information note on Verifactu (5 October 2026): hacienda.gob.es
2. Orden HAC/1028/2026, de 2 de octubre, regulating the public e-invoicing solution: boe.es
3. Agencia Tributaria, "Facturación electrónica obligatoria" (31 March 2026), on Royal Decree 238/2026: agenciatributaria.gob.es
4. Real Decreto 1007/2023, de 5 de diciembre, regulating invoicing software systems: boe.es
5. Ley 58/2003, de 17 de diciembre, General Tributaria (article 201 bis): boe.es
6. Council Directive (EU) 2025/516 on VAT in the Digital Age (ViDA): eur-lex.europa.eu
7. elEconomista, "Hacienda vuelve a retrasar la entrada en vigor de Verifactu hasta octubre de 2028" (5 October 2026): eleconomista.es