Verifactu postponed: when it comes into force in 2027, which law sets the dates and what to do in the meantime

Verifactu: when it comes into force after the postponement

The current dates are in the fourth final provision (disposición final cuarta) of Real Decreto 1007/2023, as worded by the first final provision of Real Decreto-ley 15/2025, of 2 December. The regulation sorts the obliged parties by the tax they pay, following its article 3:

Note the word «before»: in practice, the last invoice an SL (Spanish limited company) can issue with non-compliant software is the one dated 31 December 2026, and for an autónomo, the one dated 30 June 2027. The AEAT (Agencia Tributaria, the Spanish tax agency) says the same in its FAQ on the testing period.

Two clarifications that prevent nasty surprises. First: the regulation applies to anyone who uses a computer system to invoice «even if they only use it for part of their activity» (art. 3.1). If you issue most of your invoices by hand but some come out of an invoicing program, you are covered, and according to the AEAT all your invoicing must then go through that system. On the other hand, a Word or Excel template you only use to fill in, print and keep invoices is not an invoicing system; it is one if it also generates your libros registro (the mandatory tax record books) or your accounts (for example, with a macro). Both criteria are in the AEAT FAQ on the scope of application. Second: an SL does not inherit its shareholders' date. The company, which pays Impuesto sobre Sociedades, follows the January date; a shareholder's own self-employed activity follows the July date. If you have both, work to the earlier date.

From 1 July 2025 to 2027: the two Verifactu delays, in order

1. 6 December 2023. The BOE publishes RD 1007/2023. Its fourth final provision required everyone listed in article 3.1 to have their systems up and running «before 1 July 2025».
2. 28 October 2024. Orden HAC/1177/2024, with the technical specifications, is published. It comes into force the following day, and with it the software producers' nine-month period begins.
3. 2 April 2025. First postponement: Real Decreto 254/2025, of 1 April, moves the date to 1 January 2026 for companies and 1 July 2026 for everyone else.
4. 3 December 2025. Second postponement: Real Decreto-ley 15/2025 sets 1 January 2027 and 1 July 2027. It comes into force on 4 December, less than a month before the date it replaced.
5. 11 December 2025. The Congreso (the lower house of Parliament) ratifies (convalida) the royal decree-law (resolution published in the BOE on 16 December 2025). Since then the 2027 dates have been final.

Two details of this second delay. The vehicle: the change sits inside a royal decree-law whose title begins with «urgent measures to encourage investment activity by local authorities and autonomous communities», so many people did not find out in time. And the form: so that RD 1007/2023 would not be raised to the rank of law, the second final provision of the royal decree-law states that the amendment «does not alter the regulatory rank». In plain terms: to move the dates again, the Government would only need a real decreto (an ordinary royal decree).

That does not mean there will be a third postponement. As at 26 September 2026, the consolidated text in the BOE shows no later amendment of the fourth final provision, and the AEAT information note on the extended deadline still announces the same dates. Plan around them.

Why Verifactu was delayed: what the rules themselves say

Plenty of explanations for the Verifactu delay are doing the rounds; what can be verified are the reasons the Government wrote into the preambles of the two rules:

• First delay (RD 254/2025): «the very length of the procedure for its processing and approval» and «the late publication of Orden HAC/1177/2024», which arrived on 28 October 2024 and left users no room to change software before July 2025.
• Why autónomos come later: the same preamble justifies the extra six months for the other obliged parties because they «are not subject to the same obligations» as companies, which may lead to «not habitually using computer systems». Put simply: many autónomos invoice without software and need more time.
• Second delay (RDL 15/2025): «circumstances persist that justify a further extension of the enforceability period, driven both by the necessary adaptation of computerised invoicing systems and by the advisability of ensuring an orderly and uniform roll-out across the business community as a whole». The urgency that allows a royal decree-law is about the calendar: without it, the requirements would have been enforceable «on the coming 1 January 2026».

The practical reading is that the postponement is not a change of mind on the substance. Neither rule touches the technical requirements, the two modes or the penalties. RDL 15/2025 only moves the calendar; RD 254/2025 also adjusted two articles of limited scope in the regulation: article 4, on invoices issued by the customer or by a third party, and article 6, on delegating compliance. The goal is still the one set by article 29.2.j) of the Ley General Tributaria (LGT, Spain's General Tax Law): invoicing software must guarantee «the integrity, preservation, accessibility, legibility, traceability and unalterability of the records». Whoever adapted early has not wasted the effort; whoever has not started has simply gained time.

What does not change with the Verifactu postponement

RDL 15/2025 only changes the date: requirements, modes, the declaración responsable (the producer's statement of compliance) and penalties stay as they were. This is what does not move:

• The system requirements. The software must generate a registro de facturación (invoicing record) for every invoice, chained to the previous one through a hash (a code calculated from the previous record), and print a QR code on the invoice. The requirements in article 8 of the regulation are the same whether the date is 2025 or 2027.
• The two modes. VERI*FACTU, with continuous submission of the records to the AEAT (art. 16), or non-VERI*FACTU, with no submission but an electronic signature on each record. The public alternative in article 7.b) also remains: the AEAT's free application, which the rule treats as a VERI*FACTU system for all purposes (art. 16.4). If you are torn between that and a commercial program, read when the AEAT's free app is enough.
• The software producers' obligation. It has not moved: since late July 2025 they may only offer compliant products, so you can already demand this from your supplier.
• The declaración responsable. This is the document in which the producer attests that its system complies (art. 13 of the regulation). It must appear «in writing and visibly in the computer system itself in each of its versions», and its minimum content is set by article 15 of Orden HAC/1177/2024, which requires it to begin with the heading «DECLARACIÓN RESPONSABLE DEL SISTEMA INFORMÁTICO DE FACTURACIÓN». The «certification» mentioned by the law and by art. 13.1 of the regulation is that statement by the producer itself: the AEAT does not issue it and there is no official approval scheme.
• Who is left out. Anyone who keeps their IVA (Spanish VAT) record books through the SII (Suministro Inmediato de Información, near real-time reporting to the AEAT; art. 3.3 of the regulation), and anyone whose tax address is in the Basque Country or Navarre, which follow their own foral (regional) rules (art. 1.3).
• The penalties. Article 201 bis of the Ley General Tributaria has not been touched; the figures are further down.
• Electronic invoicing between businesses. It is a different obligation, with a different calendar, and the Verifactu postponement does not move it. It is imposed by article 12 of Ley 18/2022 (the Ley Crea y Crece, the business creation and growth law) and implemented by Real Decreto 238/2026. Under its fourth final provision, for businesses whose volume of operations exceeded 8 million euros in the previous year it will apply twelve months after the entry into force of the ministerial order for the AEAT's public solution, and for everyone else twenty-four months after it. As at the date of this guide, that order does not appear in the BOE. It is covered in detail in the guide to mandatory electronic invoicing.

If you already invoice with a Verifactu system: you can carry on

If you adapted for 2025 or 2026, you were not too hasty: the work is done and you can keep using it. The regulation allows anyone obliged to send their invoicing records to the AEAT voluntarily (art. 15), and a system that does so continuously is, by definition, a VERI*FACTU system (art. 16.1).

The usual question is whether you are locked in. Article 16.5 says that opting for VERI*FACTU is deemed to happen when you start sending records systematically, and that it lasts «at least until the end of the calendar year» of the first submission. But the AEAT has clarified in its FAQ that this does not bind you while you are not yet obliged: the period before your date «is a testing period». Until 31 December 2026 (companies) or 30 June 2027 (everyone else), you can stop sending records and go back to invoicing with another system, even an old non-compliant one. From your date onwards, if you start sending with VERI*FACTU, you will have to stay with it at least until 31 December of that year.

Continuing to send early has concrete advantages:

• You catch configuration errors (series, customers' NIF (tax ID) numbers, IVA rates) while you are not yet exposed to the penalty for the system.
• Your customers can check your invoices by scanning the QR code, which is exactly what article 17 of the regulation provides for.
• You can review the records you have sent in the sede electrónica (the AEAT's online portal), using the invoicing records enquiry service on the AEAT's Verifactu page.

What voluntary submission does not do is replace other obligations. The AEAT itself warns in its FAQ on VERI*FACTU systems that using them does not exempt you from filing the informative returns, and your libros registro remain mandatory (the autónomo's books, one by one, are in this guide).

What to do with your old software and your invoice history

Can you keep the old program to look up past invoices? The AEAT answers this in its FAQ. The possession offence in article 201 bis.2 of the Ley General Tributaria refers to possession «with a view to the invoicing functionality». Keeping non-compliant software is only allowed «if and only if it can be proven that invoices can NO LONGER be issued with it».

In practice you have three routes, from safest to least safe:

1. Export and uninstall. You take out the whole history (invoices as PDFs, listings and data in an open format) and remove the program. This is what the AEAT describes as «most advisable».
2. Block issuing. If the producer allows it, you change the program so that it is impossible to issue new invoices from a given date. It then stops being an invoicing system.
3. Update. Ask the producer whether there is a compliant version: according to the AEAT, «this possibility is usually very common».

What is not wise is keeping the old program working «just in case» after your date. If a tax audit turns up a non-compliant system capable of issuing invoices, the AEAT considers that mere possession is already an offence, although it says it will weigh the conduct and responsibility of the person concerned. And remember that old invoices must still be kept for the legal retention periods: exporting is not deleting.

If you invoice with a spreadsheet, apply the AEAT's criterion: it does not affect you as long as you only use it to fill in, print and keep invoices; if it also generates your libros registro or your accounts, it is an invoicing system and must comply. When in doubt, invoice with compliant software or the AEAT app and use the spreadsheet only for internal control (how to keep the books without knowing accounting).

Quarter-by-quarter checklist until your date

With the current dates, an SL has one quarter left and an autónomo has three. Fit the tasks around the deadlines for your tax returns (modelos) in the 2026-2027 tax calendar so the end of a quarter does not catch you out.

If you have an SL (date: before 1 January 2027)

• October 2026: list everything that issues invoices or receipts (invoicing program, TPV or point-of-sale terminal, online shop, ERP or business management software). Each one is an invoicing system; Word or Excel templates only count if they also generate your books or your accounts. Ask each supplier for its declaración responsable and check that it mentions the version you use.
• November 2026: review your invoice series: consecutive numbering within each series, with no gaps, and facturas rectificativas (corrective invoices) in their own series, as required by art. 6.1.a) of the Invoicing Regulation. Sign up for the final system, load customers, products and IVA rates, and issue test invoices.
• December 2026: decide on the mode (VERI*FACTU or not), close the old program's series with the last invoice of 2026, export the history and uninstall or block the old program.

If you are an autónomo (date: before 1 July 2027). If you already followed the timetable in the Verifactu for autónomos guide, this list adjusts it to the current date:

• Fourth quarter of 2026 (October to December): take stock of how you invoice today and clean up your series. Use the year-end close to check there are no skipped numbers or duplicate invoices; if you use several series (for example, one for facturas simplificadas, simplified invoices), check that each one is consecutive on its own. If your business is small, consider whether the AEAT's free app is enough for you.
• First quarter of 2027 (January to March): choose a system. Ask for the declaración responsable, check that you can export your data and test the program with your real situation: several IVA rates, IRPF withholdings if you are a professional, foreign customers. If you work with a gestor (tax adviser), ask them in what format they want to receive your invoices (how to work with your gestor).
• Second quarter of 2027 (April to June): migrate and invoice for real with the new system, in voluntary VERI*FACTU mode if you want to rehearse submission. Before 30 June, export the history and retire the old program (and the templates, if you use them for anything beyond filling in and printing).

If you sell online, the plugin that generates your shop's invoices is also an invoicing system (invoicing in an online shop). kontora issues invoices with gap-free series and numbering, reminds you of tax deadlines and prepares your returns box by box from your accounts; whichever program you invoice with, insist on its declaración responsable before your date.

What not to do while you wait (and why not to count on another moratorium)

• Buying a TPV or a program «with Verifactu» without seeing the declaración responsable. The marketing label is worth nothing; the document required by article 13 of the regulation is what counts. If the seller does not show it to you before you pay, do not buy, and check that it covers the exact version you are going to install.
• Believing a program is «approved» or «certified» by Hacienda (the Spanish tax authorities). Hacienda does not approve invoicing software: compliance is shown by the producer's own statement, under its own responsibility.
• Betting everything on another Verifactu moratorium. There is currently no rule that provides for one. If it does not come, the difference between having adapted and not having done so is a fixed fine per financial year.
• Mixing up Verifactu and electronic invoicing. They are separate obligations: do not accept an electronic invoicing date that the BOE has not yet set, and do not assume one is covered because you comply with the other.
• Deleting or renumbering invoices to tidy up your history. Consecutive numbering is an obligation under the Invoicing Regulation that long predates Verifactu. Errors are corrected with corrective invoices, not by rewriting the past. If you are starting from scratch, what your first invoice must include is a useful reference.

Penalties: what you risk if you are late

The fines are in article 201 bis of the Ley General Tributaria, in force since 11 October 2021 and unchanged by the postponement. They are fixed amounts, not a percentage of your turnover, and the offences are classed as serious (the general background is in what Verifactu is):

• User: 50,000 € for each financial year for possessing systems that do not comply with article 29.2.j) of the LGT, that are not duly certified when they should be, or that have been altered or modified (art. 201 bis.2 and .4).
• Producer or seller: 150,000 € for each financial year with sales and for each different type of system that, among other cases, allows separate sets of accounts to be kept, sales to go unrecorded or recorded sales to be altered, or that does not meet the technical specifications (art. 201 bis.1 and .4).
• Producer, for lack of certification: 1,000 € for each system sold without it (art. 201 bis.1.f and .4).

The «certification» the law refers to is the producer's declaración responsable (art. 13.1 of the regulation): there is no other.

What does the postponement change? Only when it becomes enforceable against you: until your date arrives, the regulation does not require you to have a compliant system. From your date, invoicing with a non-compliant system, or having one installed and capable of invoicing, is the conduct that, according to the AEAT, falls under art. 201 bis.2. Anyone already penalised as a producer cannot also be penalised for possession (art. 201 bis.2). For the procedure, see the glossary entry on sanción tributaria (tax penalty).

Verifactu, SII and TicketBAI: how they differ

All three aim to make sure sales cannot be hidden or altered, but they apply to different groups and do not stack:

Two practical consequences. If you are in the SII, even voluntarily, Verifactu does not apply to you (art. 3.3 of the regulation) and your invoices must not carry the tax QR code, as the AEAT points out in its FAQ on the scope of application; joining the SII just to avoid it rarely pays off for a small business: talk to your adviser first. And if your tax address is in the Basque Country, TicketBAI applies to you rather than Verifactu, even if you sell to customers in the rest of Spain; in Navarre its own foral rules apply (art. 1.3). If you have a company, go over the tax and accounting obligations of an SL.

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