Notes · AI, data and rules

Spain plans to delay VeriFactu to October 2028. The clock for business-to-business e-invoicing, on the other hand, is already running.

What is being delayed and what is not, the dates set by an order already in force, what is not yet known, and why an invoice’s data is decided on the first form.

Daniel Esteban Feo7 min read

Picture this: the finance team of a boutique hotel group in Ibiza changed its invoicing software in the spring to be ready for VeriFactu. In October they read that the Spanish Treasury wants to delay it again, and they decide to forget about it until 2028. That same week another clock started, the one for business-to-business e-invoicing, and nobody in the group has connected it with the first.

Delays get far more attention than the dates that hold. In Spanish invoicing in 2026, that is exactly what is happening.

What is being delayed, if it is approved.

VeriFactu is Spain’s regulation on invoicing software (Royal Decree 1007/2023): the program used to issue invoices must guarantee that records cannot be altered and can be sent to the tax authority. After Royal Decree-law 15/2025, the published deadlines are 1 January 2027 for companies filing corporate income tax and 1 July 2027 for everyone else.

On 5 October 2026, the Ministry of Finance published an information note with a plan: to delay the outstanding VeriFactu obligations to October 2028, so that they coincide with mandatory e-invoicing for businesses with annual turnover of up to 8 million euros. The same note says the requirements for integrity, retention, traceability and immutability will remain substantially equivalent. It is an announcement, not a rule: until it is published in the Official State Gazette, the tax agency still lists the 2027 dates.

What is not being delayed.

A day later, on 6 October 2026, Order HAC/1028/2026, which regulates the public e-invoicing solution, came into force. According to the tax agency, that date starts the calendar for mandatory e-invoicing between businesses and professionals. Issuing and receiving e-invoices will be required from 6 October 2027 for those whose turnover exceeded 8 million euros in the previous year, who must also attach a readable PDF during the first year. For everyone else, from 6 October 2028.

The obligation to report the status of invoices and payments follows the same calendar for large companies and for other legal entities, and arrives on 6 October 2029 for self-employed individuals. These dates are not a plan: they are set by an order that has been published and is in force.

What I do not know.

I do not know when, or by which instrument, the VeriFactu delay will be approved, or whether anything else will change along the way. Mandatory e-invoicing covers invoices between businesses and professionals: those a clinic, a hotel or an estate agency issues to other companies and those it receives from suppliers. Exactly what applies to your business, and from when, is for your tax adviser to confirm. I am not a tax adviser, and this note is no substitute for that advice.

The blind spot: the invoice starts on the website.

VeriFactu and e-invoicing are discussed as if they were matters for the invoicing software. But an invoice’s data is collected much earlier: when a company books a retreat at a hotel, arranges health checks for its team or instructs an estate agency. If the website form does not ask for the company name and tax number when needed, someone will have to copy them by hand later, and every manual copy is a possible error in a record that, under VeriFactu, cannot be changed without leaving a trace.

A delay changes the date of the exam. It does not change the syllabus.

Where I stand.

I think waiting for the last date is the most expensive decision, because it means changing twice: once for VeriFactu and once for e-invoicing. The sensible thing is to do it once and properly, with software whose vendor commits in writing to both rules, and with data flowing without copies from the first contact to the invoice. That is useful automation, not technology for its own sake. What needs automating does not change with the date: the right data, once, from the first form.

What I would check.

  • Whom you invoice. What share of your invoices goes to businesses and professionals, and how many you receive from suppliers.
  • Your calendar. Whether your turnover exceeds 8 million euros, because that brings your date forward by a year.
  • Your software. Whether the vendor confirms VeriFactu and e-invoicing in writing, with dates.
  • The website form. Whether it asks for a company’s tax details when the person booking or hiring is a company.
  • Manual copies. How many times a piece of data is retyped between the website, the calendar or the CRM and the invoice.

Where to start.

  1. This week

    Find out which calendar applies

    With your tax adviser: turnover, invoices to businesses and the dates that apply to you.

  2. This month

    Ask your vendor

    What your invoicing software will do about VeriFactu and e-invoicing, and when, in writing.

  3. This quarter

    Connect the entry point

    Data from the website, the calendar or the CRM should reach the invoice without being retyped.

  4. Before each date

    Test

    Issue and receive test invoices with your usual clients and suppliers, with time to fix problems.

Follow a single piece of data for a day. Take the tax number of a customer who booked or bought on your website last week and find how many times it has been typed again by hand since: in the email, in the spreadsheet, in the invoicing software.

Every time someone copied it, they could have made a mistake. When electronic invoicing between businesses becomes mandatory, who will spot the error first, your team or your customer’s software?

If you would like me to review how your customers’ data travels today from the website to the invoice, start with the Strategic Diagnostic. What applies to you, and from when, is for your tax adviser to decide, not a designer.