When is VeriFactu mandatory? Current dates and announced postponement

Short answer: for businesses subject to the regulation that invoice with software, the BOE requires the system to be adapted before January 1, 2027 for corporate income tax payers and before July 1, 2027 for everyone else, including the self-employed. Hacienda has announced a postponement until October 2028, with no set day and no approved rule. The AEAT keeps both 2027 dates.

Mandatory VeriFactu dates for companies and the self-employed in Spain

These dates apply to users of computerized invoicing systems subject to Real Decreto 1007/2023. Those in the SII or taxed under regional (foral) rules are outside its scope; those who invoice exclusively by hand are also outside it. The fourth final provision of the regulation, amended by Real Decreto-ley 15/2025, sets the dates in force.

Last regulatory verification: October 15, 2026. Hacienda’s announcement does not replace the BOE dates. Sources: BOE, Hacienda’s note and AEAT portal.

"Antes del" (before) means that the last day is December 31, 2026 or June 30, 2027. No VeriFactu date has depended on the size of the business. October 2027 is only the B2B electronic invoicing date for those who exceeded €8 million. The €6,010,121.04 that some tables repeat is the threshold of the SII (Spain's real-time VAT reporting system). Businesses in the SII are outside VeriFactu.

What is mandatory is having the system adapted, while sending each record to the AEAT, in the VERI*FACTU mode, is optional. The regulation has been in force since December 7, 2023, and the postponements have only moved the date from which it is enforced.

When VeriFactu is mandatory for a bar or restaurant

Two examples to place your venue, assuming it invoices with a POS, is subject to the regulation and is not in the SII:

• Restaurant owned by an SL (limited company): its system must be adapted before January 1, 2027, however small the company.
• Bar owned by a self-employed person: its system must be adapted before July 1, 2027. Being in the modules regime does not by itself exclude it; what matters is whether its POS issues invoices.

In both cases, the October 2028 announcement still needs a rule. To prepare your equipment, use the VeriFactu restaurant POS checklist (in Spanish) and the POS adaptation guide.

The receipt (simplified invoice) that comes out of the POS is subject to VeriFactu but not to B2B electronic invoicing. An invoice with the NIF and address of a client business established in Spain, whether full or a qualified simplified invoice, will fall under B2B electronic invoicing when the restaurant's turn comes (article 4.1 of Real Decreto 238/2026).

If the restaurant does not designate a platform to receive invoices, its default mailbox is the AEAT's public e-invoicing solution. Immediate payment has its own rule (article 7.4 of Orden HAC/1028/2026). If the invoice already shows the transaction date as the payment date, and that date is not later than the date of issue, the payment is deemed reported.

If it enters into force, the postponement will delay the obligation to have an adapted POS for those it covers and, with it, the fine for having the POS uncertified. We recommend replacing a non-adapted POS before whatever date is in the BOE at the time. The operational side is in what VeriFactu requires of a bar or restaurant POS.

At Plattio, invoicing complies with Real Decreto 1007/2023 in the VERI*FACTU mode and is integrated with the Spanish tax agency's system, in Spain only. A recorded sale is corrected with a refund and a new charge, without rewriting it. The VeriFactu chain can always be exported from Plattio's POS.

Who is outside these dates

Businesses that pay tax under the foral rules of the Basque Country stay with TicketBAI. Those that pay tax under Navarre's foral rules have neither system in force. The announced postponement does not affect them.

Anyone who keeps their VAT books through the SII, whether required to or voluntarily, is also outside VeriFactu (article 3.3 of Real Decreto 1007/2023). Nor does it cover anyone who invoices exclusively by hand.

See Plattio's POS · See a guided demo

What the Ministerio de Hacienda announced on October 5, 2026

On October 5, 2026, the Ministerio de Hacienda's press office circulated an information note setting out a plan to postpone the pending obligations of Real Decreto 1007/2023 "hasta octubre de 2028" (until October 2028). No rule has been approved.

"[…] it has been considered appropriate to align the implementation calendars of the electronic invoicing rules for SMEs and the self-employed and of the Regulation on computerized invoicing systems and, therefore, to proceed with postponing, until October 2028, the obligations of Real Decreto 1007/2023, of December 5, that are still pending application, so that they coincide with mandatory electronic invoicing for businesses and professionals whose annual turnover does not exceed €8 million."

The wording "it has been considered appropriate […] to proceed" expresses an intention. The note does not say which rule will be used or when. Nor does it mention manufacturers, the trial period, penalties, or the territories with their own (foral) tax regimes. On September 29, the finance minister was still defending the 2027 dates in the Senate: "Until then, we are in a trial period."

October 2028, with no day set

The note sets no day and does not clarify whether the wording will be "antes del" (before) or "desde el" (from). The day that is circulating, the 6th, comes from the AEAT news item on electronic invoicing.

"After 24 months (October 6, 2028): All other businesses and professionals: obligation to issue, send, and receive electronic invoices."

Real Decreto 1007/2023 has always used "antes del" (before), and applying the 6th to VeriFactu is an inference.

Where is the note, and what has the AEAT done?

The note was published only as a PDF, with no entry in the Ministerio de Hacienda's newsroom. The AEAT links to it from its VeriFactu portal as "Previsión de ampliación del plazo" (planned extension of the deadline).

The AEAT has not published a note of its own on 2028. Its information note calls the 2027 dates "new approved deadlines", and its FAQs, "Updated as of July 21, 2026", repeat them. The VERI*FACTU Informador, the AEAT's online help tool, keeps 2027 and only adds a sentence beginning "However" that refers to the note.

The AEAT circulates the note, but approving the postponement is up to the Government in the Council of Ministers. The October 5 meeting deliberated on the dissolution of the Cortes, and the October 6 meeting did not deal with VeriFactu, according to its official summary.

Does the postponement include companies?

No official text published up to October 15, 2026 clarifies whether the postponement to October 2028 includes corporate income tax payers, whose legal date is still before January 1, 2027. A small SL (limited company) also pays that tax. On size, the note allows two readings.

• Narrow reading. The note anchors the date to electronic invoicing for those not exceeding €8 million. The internal title of the PDF file, which you cannot see when you open it, speaks of VeriFactu "for SMEs and the self-employed", a hint of the approach.
• Broad reading. The visible title speaks of "businesses and professionals", and the text plans to postpone "the pending obligations" without limiting who is covered. The Ministerio de Hacienda already used "SMEs and the self-employed" in December 2025 for a postponement that also included companies.

The two readings only diverge for those above €8 million in volume of operations. Such a business also exceeds the €6,010,121.04 that makes the SII mandatory and, as a general rule, is outside VeriFactu. For a small SL the question remains open, because the note gives a single date and the BOE gives the SL a date of its own. The AEAT still gives two dates, and the unified dates that some websites publish are their own readings.

VeriFactu and B2B electronic invoicing, two separate calendars

Orden HAC/1028/2026, published in the BOE on October 5, 2026, starts the clock on the deadlines for electronic invoicing between businesses, but it does not change the VeriFactu dates. It entered into force the following day, "thereby starting the countdown of the deadlines" of Real Decreto 238/2026, according to its sole final provision.

That royal decree counts "twelve months" and "twenty-four months", and the AEAT calculates the day. Those who exceeded €8 million in volume of operations in the prior year start on October 6, 2027. Everyone else starts on October 6, 2028. On that day, companies up to €8 million also start reporting invoice statuses and payments. The self-employed and comunidades de bienes will do so from October 6, 2029.

The note speaks of "annual turnover", but the threshold is measured in VAT volume of operations for the prior year, and it is different from the SII threshold. In its general questions, the AEAT makes it clear that invoicing records "are in no case electronic invoices". No official text says that issuing B2B electronic invoices exempts you from VeriFactu.

What the announcement does not change

Since July 29, 2025, invoicing software manufacturers may only sell adapted systems. The Ministerio de Hacienda note does not change that obligation. According to the AEAT's FAQs for developers, the exception is "maintenance contracts in force". Those systems are adapted on their users' dates.

The fines in article 201 bis of the Ley General Tributaria, in force since October 11, 2021, do not change either. The manufacturer faces €150,000 per financial year with sales and per type of system that allows keeping double books or hiding or altering transactions. Since July 29, 2025, the same applies for breaching the technical specifications, plus €1,000 for each system sold without certification. The user faces €50,000 per financial year for having a non-compliant system that is not certified when it should be, or that is certified but has been altered. The lack of certification can only be penalized from the user's obligation date. Using an adapted system without sending the records to the AEAT is not an infringement.

The note states that the technical requirements will be kept "en términos sustancialmente equivalentes" (in substantially equivalent terms). But it also announces, with no date or text, a second reform linked to ViDA, the European VAT in the Digital Age package. Software certification is still a compliance declaration (declaración responsable) by the producer itself, with no AEAT approval. What the regulation requires of a POS today is covered in the VeriFactu guide for hospitality.

The four VeriFactu dates, from 2025 to 2028

VeriFactu has had three dates in the BOE and has a fourth, October 2028, that has only been announced. The two approved postponements came with Real Decreto 254/2025 and with Royal Decree-Law 15/2025.

If the announced postponement were approved as it stands, the other obligated parties would gain about 15 months, and companies about 21 if they are included. These are our own calculations, counted to early October 2028. Nobody knows whether the date will move again.

What it would take for October 2028 to become the legal date

The postponement will only change the legal date when a rule amending the fourth final provision of Real Decreto 1007/2023 is published in the BOE and enters into force.

The last two signals do not change the date on their own.

In principle, a royal decree is enough

In principle, a royal decree from the Government is enough to change the VeriFactu dates, because Royal Decree-Law 15/2025 declared that Real Decreto 1007/2023 "fully retains its nature as a regulation". That safeguard clause refers by mistake to a nonexistent "artículo 3" (article 3). The error was pointed out in Congress on December 11, 2025 and, as of October 15, 2026, it has still not been corrected in the BOE.

From the context, the soundest reading is that the clause protects the amendment of the regulation, although there is no record that any body has confirmed it. The opposite reading also has grounds. According to the Constitutional Court (STC 61/2016), a royal decree-law can raise and freeze the rank of what it amends. If the clause were not effective, only a law or another royal decree-law could move the date. No legal commentary has been found on a safeguard clause that refers to a nonexistent article.

A new royal decree-law would clear up the doubt. If a royal decree is used, the Consejo de Estado (Council of State) will give the first official reading of the clause.

Royal decree or royal decree-law

Both routes are approved by the Council of Ministers, with different procedures.

Dissolved Cortes and a caretaker government

The Cortes were dissolved on October 6, 2026. Until the November 29 elections, the Government keeps full powers to approve a royal decree, and afterwards it will be a caretaker government. Ley 50/1997, Spain's Government Act, does not bar a caretaker government from approving royal decrees, but it limits its action to ordinary business except for duly proven urgency or general interest.

On October 6, with the Cortes dissolved, the Government approved two royal decree-laws on housing. With the dissolution, bill 121/000082 lapsed. Congress had agreed to process that bill when it ratified Royal Decree-Law 15/2025. The royal decree-law remains in force.

What would happen if January 1, 2027 arrives with no rule

If January 1, 2027 arrives with no new rule in the BOE, companies outside the SII will already have to have their system adapted.

What the sources say

From January 1, 2027, a company with a non-adapted system that can still issue invoices would commit an infringement merely by having it. That is what the AEAT's FAQs say, placing it under article 201 bis.2 of the Ley General Tributaria. The AEAT adds "subject to prior assessment of the taxpayer's conduct and responsibility". The Dirección General de Tributos also ties that infringement to the date in the regulation (ruling V0482-26). Granting a moratorium or waiving penalties requires a law (article 8 of the Ley General Tributaria). Moving the regulation's date is different, because it changes the day from which that infringement can be established.

What nobody has said

There is no record that the courts or the Ministerio de Hacienda have said whether a postponement published after January 1, 2027 would benefit those who did not adapt. The rule itself could set its effects. If it does not, what would remain is the retroactive application of more favorable rules. The version in the Ley General Tributaria (article 10.2) is designed for rules that govern infringements and penalties, and it only reaches acts that are not yet final. Ley 40/2015, on the legal regime of the public sector, goes further in its article 26.2 and reaches even penalties still pending enforcement. The Supreme Court has one line of case law that applies that retroactivity when the rule completing the definition of an offense changes, and another, more restrictive one. There is no record that any court or body has placed article 201 bis.2 in either of them. Nor is there any record of a precedent, because the VeriFactu postponements and the foral ones we reviewed arrived before the date they moved.

Which date to plan around in the meantime

• Company outside the SII. The rule requires it to have its system adapted before January 1, 2027. We recommend planning around that date, because the announcement has no set day and no rule, and the AEAT keeps 2027.
• Self-employed or comunidad de bienes. The rule requires the system to be adapted and running before July 1, 2027, and we recommend the same.

In both cases, anyone already sending records with VERI*FACTU can stop sending them until their date, according to the AEAT.

Sources and method

Every fact is checked against the primary source linked next to it. The sources are consolidated texts in the BOE, the AEAT's website, the Ministerio de Hacienda note, Council of Ministers meeting summaries, records of proceedings of the Cortes, and rulings of the Dirección General de Tributos. Where two official sources disagree, the article says so. This is general information and does not replace tax advice. For a specific case (tax regime, territory, open proceedings), talk to your tax advisor.

Changelog

• October 18, 2026. Published, with the status verified on October 15.