On 5 October 2026 Spain's Ministry of Finance announced that it plans to postpone VERI*FACTU until October 2028, aligning it with mandatory e-invoicing (6 October 2028, Order HAC/1028/2026). It is not yet in the BOE: 1 January 2027 (corporate income tax payers) and 1 July 2027 (everyone else) still apply.
New to VERI*FACTU? It is the common name for Spain's Regulation on invoicing computer systems (Royal Decree 1007/2023 and Order HAC/1177/2024). Any company or professional invoicing under Spanish tax rules, including the Spanish subsidiary or branch of a foreign group, must issue invoices from software that generates a tamper-proof record of each invoice (chained hash, signature and QR code) and can optionally send those records to the Spanish Tax Agency (AEAT) in real time. It is a separate obligation from mandatory structured B2B e-invoicing, and the announcement discussed here is about making the two coincide.
What exactly the Ministry of Finance has announced
Hacienda has announced an intention, not a rule. The information note from the Ministry of Finance's press office, dated 5 October 2026, is titled «Previsión de modificación de los plazos de aplicación de las obligaciones pendientes para los empresarios y profesionales derivadas del Reglamento de sistemas informáticos de facturación (Real Decreto 1007/2023) y convergencia con el sistema de factura electrónica» ("Planned amendment of the application deadlines of the pending obligations for businesses and professionals under the Regulation on invoicing computer systems (Royal Decree 1007/2023) and convergence with the e-invoicing system"). It is one page long and states, literally, that «se ha considerado conveniente alinear los calendarios de implantación de la normativa de facturación electrónica para pymes y autónomos y del Reglamento de sistemas informáticos de facturación y, por tanto, proceder al aplazamiento de las obligaciones pendientes de aplicación del Real Decreto 1007/2023, de 5 de diciembre, hasta octubre de 2028, para hacerlas coincidir con la obligatoriedad de la factura electrónica para empresarios y profesionales cuya facturación anual no supere los 8 millones de euros» ("it has been considered appropriate to align the implementation timelines of the e-invoicing rules for SMEs and the self-employed and of the Regulation on invoicing computer systems and, therefore, to postpone the pending obligations under Royal Decree 1007/2023 of 5 December until October 2028, so that they coincide with mandatory e-invoicing for businesses and professionals whose annual turnover does not exceed 8 million euros").
The note adds two things that matter more than the date. First: «una vez aprobada dicha alineación de los calendarios» ("once that alignment of the timelines has been approved"), Hacienda will undertake «una modificación centrada en conseguir la convergencia de los ámbitos de aplicación y ciertos aspectos técnicos de la normativa vigente teniendo en cuenta los futuros requisitos de reporte digital derivados de ViDA» ("an amendment focused on achieving convergence of the scopes of application and certain technical aspects of the current rules, taking into account the future digital reporting requirements arising from ViDA"), the EU's VAT in the Digital Age reform. Second: «las exigencias establecidas en el Real Decreto 1007/2023 en materia de integridad, conservación, accesibilidad, legibilidad, trazabilidad e inalterabilidad, así como las restantes garantías técnicas del sistema, se mantendrán en términos sustancialmente equivalentes a los previstos en su desarrollo normativo actual» ("the requirements laid down in Royal Decree 1007/2023 regarding integrity, preservation, accessibility, legibility, traceability and unalterability, as well as the system's other technical guarantees, will be maintained in terms substantially equivalent to those provided for in its current implementing rules").
In plain terms: the timeline moves; the system is not dismantled. And the reason is to avoid an SME having to change its invoicing twice in twelve months, once for VERI*FACTU in 2027 and again for e-invoicing in 2028. As The Objective summed it up the same day, the Government "had already delayed entry into force by a year" and is now moving it again, this time to coincide with e-invoicing.
Is it official yet? Announced is not published
It is not official, and precision matters here because it determines which date binds you today. The VERI*FACTU dates are set in the fourth final provision of Royal Decree 1007/2023. Every time they have moved, it has been through a rule published in the BOE: Royal Decree 254/2025 moved them to 2026 and Royal Decree-Law 15/2025 of 2 December to 2027. The Spanish Tax Agency (AEAT) itself puts it this way in its note on the extended adaptation deadline: "in accordance with the amendment introduced by Royal Decree-Law 15/2025 of 2 December", corporate income tax payers must have their systems adapted before 1 January 2027 and all other obliged parties before 1 July 2027.
As of 19 October 2026 no published rule replaces those dates with October 2028. Every source we consulted says so: Fube recalls that this is an "information note from the press office" and that fixing the date requires "a provision amending the fourth final provision of Royal Decree 1007/2023"; Ponter points out that the postponement "is still pending its corresponding regulatory amendment"; Sánchez Garrido Abogados warns that "the rule formalising it has not been published in the BOE"; and Webpsilon sums it up in one sentence: "it has not yet been published in the BOE", and in the meantime "1 January 2027 (companies) and 1 July 2027 (everyone else)" remain in force.
Rule of thumb. If someone tells you VERI*FACTU "is in 2028", ask them for the BOE issue number. Until they can give it to you, your legal date is the 2027 one. What is reasonable is to plan on the assumption that the postponement will be approved, because it is the Ministry itself announcing it; what is not reasonable is to stop doing anything.
A precedent helps to calibrate: the postponement to 2027 was announced in a press release on 2 December 2025 and published as a Royal Decree-Law in the following days. This time the legal instrument has not been announced, but a change of dates in a royal decree can be made by another royal decree or by a royal decree-law; in both cases it goes through the Council of Ministers and the BOE.
The new joint timeline: VERI*FACTU and e-invoicing
Since 6 October 2026 there have been two timelines in play, and for the first time they are designed to converge. The e-invoicing timeline was activated that day with the entry into force of Order HAC/1028/2026 of 2 October (BOE of 5 October 2026), which regulates the Tax Agency's public e-invoicing solution and thereby starts the clock on the deadlines of Law 18/2022 ("Crea y Crece") and its implementing regulation, Royal Decree 238/2026. According to the AEAT itself, the deadlines run twelve, twenty-four and thirty-six months from that date. We explain it in detail in mandatory B2B e-invoicing in Spain.
| Date | Obligation | Who is affected | Legal status as of 19 Oct 2026 |
|---|---|---|---|
| 29 Jul 2025 | Only invoicing software compliant with RD 1007/2023 may be marketed | Software manufacturers and distributors | In force |
| 6 Oct 2026 | Order HAC/1028/2026 enters into force; the e-invoicing deadlines start running | All businesses and professionals | In force (BOE 5 Oct 2026) |
| 1 Jan 2027 | VERI*FACTU: compliant invoicing system (record with chained hash and QR code) | Corporate income tax payers | In force (RDL 15/2025); the Ministry plans to postpone it to October 2028 |
| 1 Jul 2027 | VERI*FACTU: compliant invoicing system | Self-employed professionals and all other obliged parties | In force (RDL 15/2025); the Ministry plans to postpone it to October 2028 |
| 6 Oct 2027 | Mandatory B2B e-invoicing plus reporting of invoice status and payments | Companies and professionals with turnover above 8 million euros | In force (Order HAC/1028/2026) |
| October 2028 | VERI*FACTU: pending obligations of RD 1007/2023 | According to the note, all obliged parties in common territory | Announced 5 Oct 2026, pending BOE |
| 6 Oct 2028 | Mandatory B2B e-invoicing; legal entities also report invoice status and payments | All other companies and professionals (8 million or less) | In force (Order HAC/1028/2026) |
| 6 Oct 2029 | Reporting of invoice status and payments | Individuals and income-attribution entities | In force (Order HAC/1028/2026) |
The correct reading of the table is this: for an SME or a self-employed professional invoicing 8 million or less, if the postponement is published, October 2028 becomes the single date for both obligations. For a company invoicing more than 8 million, e-invoicing arrives on 6 October 2027 in any case, and the note does not clarify whether its VERI*FACTU also moves to 2028 or stays in 2027; that is the point the final rule should settle. We keep the full detail in the VERI*FACTU calendar, which we will update as soon as there is a BOE publication.
What changes and what does not change with the postponement
One date changes; according to the sources consulted and pending regulatory confirmation, none of the technical requirements does. The Ministry's note is explicit that the guarantees of Royal Decree 1007/2023 will be maintained «en términos sustancialmente equivalentes» ("in substantially equivalent terms"), and the technical implementation of those guarantees is in Order HAC/1177/2024, which nobody has announced amending. This is what, as of today, stays and what moves:
| Element | Does it change? | Detail |
|---|---|---|
| Mandatory dates for the user | Yes (planned) | From 1 Jan and 1 Jul 2027 to October 2028, once the amendment is published |
| Invoicing record for every invoice | No | Registration and cancellation records with the fields of Order HAC/1177/2024 |
| Chained hash and record signature | No | Fingerprint of each record chained to the previous one; electronic signature in the non-VERI*FACTU mode |
| QR code on the invoice | No | Order HAC/1028/2026 additionally requires the VERI*FACTU QR code on the e-invoice "where applicable" |
| Voluntary submission to the AEAT (VERI*FACTU mode) | No | Still available for anyone who wants to send records from now on; we compare it in VERI*FACTU vs non-VERI*FACTU |
| Manufacturer's responsible declaration | No | Mandatory to market software since 29 July 2025 |
| Penalty regime (art. 201 bis LGT) | No | 50,000 € per tax year for the user and 150,000 € for the manufacturer of non-compliant software |
| Scope and technical aspects in the medium term | Pending | The note announces a later amendment to converge with ViDA; no text and no date |
The row worth watching most is the last one. Hacienda has said that, once the timelines are aligned, it will touch the scope of application and «ciertos aspectos técnicos» ("certain technical aspects") to converge with ViDA's digital reporting requirements. There is no draft, so nobody can tell you today what will change; what you can do is require your vendor's contractual commitment to update the software when it is published, at no extra cost. The current technical requirements remain the reference.
What happens if you have already adapted or had the project under way
If you already invoice with a compliant system, you have lost nothing: your software remains valid according to the sources consulted, pending regulatory confirmation, and what you have gained is two unhurried years to absorb e-invoicing with the same system. Ponter sums it up for those halfway through: "those who have already started the process can continue it without haste". It is the right advice, with three caveats.
- If you already send records to the AEAT in VERI*FACTU mode, keep doing it. Voluntary submission does not disappear with the postponement, and having months of records submitted without incidents is the best proof that the system works before it becomes mandatory.
- If you are in the middle of a project, do not stop it; change its scope. A VERI*FACTU project that ends in March 2027 and an e-invoicing project that starts in 2028 are the same work done twice: taking stock of the points where invoices are issued, cleaning customer master data and connecting the ERP. Do it once.
- If you signed with a vendor with a delivery date tied to 2027, review the contract. The postponement does not oblige you to renegotiate anything, but it is a good moment to demand two clauses: a free update when the Ministry publishes the convergence with ViDA, and e-invoicing support in the same product.
What you should not do is what happened with the two previous postponements: many SMEs read the delay as "no longer needed" and in December 2025 found themselves back at square one. A postponement is time, and time is only worth something if it is used.
Five practical decisions for an SME this week
An SME does not need a two-year plan; it needs five decisions that can be taken in a one-hour meeting. These are the five, in the order in which we work through them with clients:
Choose your own go-live date, for example the first quarter of 2028 if you are an SME, or the second half of 2027 if you invoice more than 8 million and e-invoicing reaches you on 6 October 2027. The legal dates have moved three times; yours should not move with them.
Both obligations touch the same point: the moment each invoice is issued. The invoicing record with hash and QR code (VERI*FACTU) and the structured format sent to the recipient and to the public solution (e-invoicing) must come out of the same system. Whoever sets them up separately will pay for two integrations and maintain two reconciliations.
The postponement takes the pressure off the most expensive decision. If your ERP works, the sensible thing is to adapt it with a module or an external adapter rather than migrate because of a tax obligation; if you were going to replace it anyway, you now have room to do it properly. We go into it in how to adapt your ERP to VERI*FACTU and in the comparison of VERI*FACTU software.
Three questions in writing: does it have a responsible declaration of compliance with RD 1007/2023? Does it commit to updating the software when the Ministry publishes the convergence with ViDA, at no cost? Will it include e-invoicing in the same product or sell it separately? If one answer is "we'll see", you have located the risk.
There is no need to wait for the obligation to send records to the AEAT. Choosing one invoice series or one branch, activating VERI*FACTU mode and accumulating months of submissions without incidents is the cheapest way to discover data problems (malformed tax IDs, duplicate series, badly chained corrective invoices) while there are still no penalties.
If you are taxed in the Basque Country or Navarre, none of this replaces the timeline of your regional tax authority (Hacienda Foral): TicketBAI, Batuz and the Navarrese regional rules have their own dates and do not depend on Royal Decree 1007/2023.
How Dokuflex handles it
Dokuflex, a low-code BPM platform with AI, approaches VERI*FACTU with the idea the postponement has just vindicated: adapt calmly and with the ERP you already use. The Dokuflex VERI*FACTU adapter connects to SAP, Sage, A3, Holded and Dynamics, and to bespoke systems via API or CSV, and generates for every invoice the invoicing record with the chained hash, the signature and the QR code required by Royal Decree 1007/2023 and Order HAC/1177/2024, with submission to the AEAT in VERI*FACTU mode. The existing invoicing system stays where it is.
What it brings in the 2028 scenario:
- A single exit point for both obligations. The same flow that generates the VERI*FACTU record can issue the structured e-invoice when your date arrives, without a second ERP integration.
- Voluntary submission from day one. You can activate submission to the AEAT by invoice series or by branch and check data quality before it becomes mandatory.
- Regulatory updates included. When the Ministry publishes the convergence with ViDA, the change is made in the adapter, not in your ERP.
- Up and running in 48 hours with the existing connectors, so that the internal date you set in decision 1 is a real date.
No alarmism: nobody has to change ERP because of VERI*FACTU, neither in 2027 nor in 2028. If you want to go through your specific timeline with someone who does it every day, book a 20-minute session.
Frequently asked questions
Is the postponement of VERI*FACTU to October 2028 official yet?+
No. What exists as of 19 October 2026 is an information note from the press office of the Spanish Ministry of Finance, dated 5 October 2026, which speaks of a «previsión de modificación de los plazos» (a planned amendment of the deadlines). For the postponement to take effect, a rule published in the BOE must amend the fourth final provision of Royal Decree 1007/2023, as was done with Royal Decree-Law 15/2025 to move the dates to 2027. Until then, the legally binding dates are 1 January 2027 for corporate income tax payers and 1 July 2027 for everyone else.
Can I wait until 2028 to adapt my invoicing?+
Legally, no, as long as the postponement is not in the BOE: the obligation in force is still the 2027 one. In practice, the amendment is very likely to be approved, because the AEAT itself already lists it as planned, but waiting for the deadline without doing anything is the worst option: in October 2028 VERI*FACTU and mandatory e-invoicing will coincide for anyone invoicing 8 million euros or less, and software vendors will have a backlog of demand. The sensible course is to continue the project calmly and design it to meet both obligations at once.
If my software is already adapted to VERI*FACTU, is it still valid or will I have to change it?+
According to the Ministry's note, the requirements of Royal Decree 1007/2023 on integrity, preservation, accessibility, legibility, traceability and unalterability, and the system's other technical guarantees, will be maintained «en términos sustancialmente equivalentes» (in substantially equivalent terms) to the current ones. A system that today generates the invoicing record with a chained hash and the QR code in accordance with Order HAC/1177/2024 will remain valid according to the sources consulted, pending regulatory confirmation. The note does announce a later amendment to converge the scope of application and certain technical aspects with the ViDA requirements, so it is worth requiring your vendor's commitment to update the software when it is published.
Does the postponement affect Navarre and the Basque Country (TicketBAI and Batuz)?+
The Ministry's note refers to Royal Decree 1007/2023, which is the legislation for Spain's common territory. The provincial councils of Álava, Bizkaia and Gipuzkoa have their own system (TicketBAI and, in Bizkaia, Batuz) with their own timelines, and Navarre has its own regional rules. We are not aware of any change to those timelines resulting from the national announcement; if you are taxed in one of those territories, your reference is your regional tax authority, not this note.
What happens to VERI*FACTU penalties in the meantime?+
The penalty regime does not change with the announcement. It is set out in Article 201 bis of Spain's General Tax Act (LGT): up to 50,000 euros per tax year for anyone using an invoicing system that does not meet the requirements, and 150,000 euros per tax year for anyone manufacturing or marketing non-compliant software. Penalties on the user apply only once the obligation to use a compliant system is enforceable, that is, on the 2027 dates currently in force or on the 2028 ones if the postponement is published. For manufacturers, the obligation to market only compliant software has been enforceable since 29 July 2025.
Does the mandatory e-invoicing date change too?+
No. E-invoicing between businesses and professionals has its own timeline, activated by Order HAC/1028/2026 (BOE of 5 October 2026, in force since 6 October 2026): mandatory on 6 October 2027 for those with turnover above 8 million euros and on 6 October 2028 for everyone else. What the Ministry's note does is move VERI*FACTU towards that second date, not the other way round.
My company invoices more than 8 million: is my VERI*FACTU also postponed to 2028?+
The note speaks of postponing «las obligaciones pendientes de aplicación del Real Decreto 1007/2023» (the pending obligations under Royal Decree 1007/2023) without distinguishing by size, so the literal reading is that the postponement covers all obliged parties in common territory. But the stated reason for the postponement is to align VERI*FACTU with e-invoicing for those invoicing 8 million or less, and a large company will have to issue e-invoices from 6 October 2027. It is the point the note does not clarify and that the final rule should settle; until then, for a large company the date in force is still 1 January 2027.
Sources
- Spanish Ministry of Finance, information note of 5 October 2026: planned amendment of the application deadlines of Royal Decree 1007/2023 and convergence with e-invoicing (postponement until October 2028).
- Spanish Tax Agency, information note on the extended adaptation deadline: dates in force of 1 January and 1 July 2027 under Royal Decree-Law 15/2025 of 2 December.
- Spanish Ministry of Finance, press release of 2 December 2025: previous postponement of VERI*FACTU from 2026 to 2027 by royal decree-law.
- Order HAC/1028/2026 of 2 October (BOE of 5 October 2026): regulates the public e-invoicing solution and activates the mandatory e-invoicing deadlines.
- Spanish Tax Agency, public e-invoicing solution (7 October 2026): timeline at 12, 24 and 36 months from 6 October 2026.
- Royal Decree 1007/2023 of 5 December (consolidated text): Regulation on invoicing computer systems; fourth final provision (deadlines).
- The Objective, Fube, Ponter, Sánchez Garrido Abogados and Webpsilon: coverage of the announcement (5 and 6 October 2026), legal status pending BOE publication, deadlines of Order HAC/1028/2026 and penalty regime of Article 201 bis of the General Tax Act. All quotations from these Spanish-language sources are our translation.
- Status as of 19 October 2026: the postponement to October 2028 is not published in the BOE. We will revisit this article when the rule formalising it is published.
Two obligations, one project, the ERP you already have
Tell us which ERP you invoice with and how many issuing points you have, and in 20 minutes we will tell you which date binds you today, what changes if the postponement is published and how to cover VERI*FACTU and e-invoicing with a single integration. No commitment.