Spain's AEAT Proposes Verifactu Delay to October 2028, But Legal Deadlines Remain Unchanged
Spain's Tax Authority (AEAT) has announced its intention to postpone Verifactu compliance deadlines from 2027 to October 2028, aiming for convergence with mandatory B2B e-invoicing and EU digital reporting requirements. However, these new deadlines lack legal force until published in Spain's Official State Gazette (BOE), leaving the original 2027 deadlines established by Real Decreto-ley 15/2025 as the only formally binding obligations.
Key takeaways
- The AEAT has proposed postponing Verifactu deadlines to October 2028, but these lack legal force until published in the BOE.
- Verifactu and mandatory B2B e-invoicing are distinct systems with different regulatory scopes.
- Businesses must continue preparing for the 2027 Verifactu deadlines established by Real Decreto-ley 15/2025.
- The proposed October 2028 deadline should not be considered confirmed until formally amended in the BOE.
- The convergence of Verifactu, mandatory e-invoicing, and EU digital reporting requirements will shape Spain's digital taxation landscape.
Context: Verifactu's Evolving Compliance Timeline
Verifactu, Spain's billing-software certification framework, has faced multiple delays since its inception under RD 1007/2023. The current deadlines—1 January 2027 for large entities and 1 July 2027 for other businesses—were set by Real Decreto-ley 15/2025. The AEAT's recent announcement proposes pushing these deadlines to October 2028.
The stated rationale for this delay is to achieve "maximum convergence" between Verifactu and the incoming mandatory B2B e-invoicing regime, as well as alignment with future EU digital reporting requirements under the VAT in the Digital Age (ViDA) initiative. The government aims to redesign the Verifactu framework to maintain its core technical guarantees—integrity, preservation, traceability, and immutability of invoice records—while harmonizing with the e-invoicing infrastructure.
What's Changing: Legal Force vs. Announced Intent
Despite the AEAT's announcement, the proposed postponement has not been published in the BOE as of 11 October 2026. Therefore, the 2027 deadlines established by Real Decreto-ley 15/2025 remain the only legally binding obligations. Businesses and software vendors must continue preparing for these deadlines until a formal regulatory amendment is published in the BOE.
The AEAT has updated its Verifactu webpage to reflect the proposed postponement, but this update carries no legal force. The distinction between Verifactu and mandatory e-invoicing is critical: Verifactu governs billing software characteristics, while mandatory e-invoicing regulates the issuance, transmission, and receipt of invoices between trading parties.
Implications for Businesses: Compliance Risks and Planning Uncertainty
Businesses and software vendors must treat the 2027 deadlines as operative until a formal regulatory amendment appears in the BOE. The proposed October 2028 deadline should not be considered confirmed, and compliance preparations should continue based on the current legal requirements.
The delay history of Verifactu raises questions about the credibility and stability of the regulatory framework. Businesses should be cautious about adjusting their compliance timelines based on announcements that lack legal force.
Outlook: What to Watch in Spain's Digital Taxation Landscape
The convergence of Verifactu, mandatory B2B e-invoicing, and EU digital reporting requirements under ViDA will shape Spain's digital taxation landscape in the coming years. Businesses should monitor developments closely, particularly any formal regulatory amendments published in the BOE.
Additionally, the implementation of mandatory B2B e-invoicing—set to apply to businesses with annual turnover exceeding €8 million from October 2027 and to all other businesses from October 2028—will significantly impact the Spanish market. Orden HAC/1028/2026, published in the BOE on 5 October 2026 and in force from 6 October 2026, regulates Spain's public e-invoicing solution.
Frequently asked questions
- What are the current legally binding Verifactu compliance deadlines?
- The current deadlines are 1 January 2027 for large entities and 1 July 2027 for other businesses, as established by Real Decreto-ley 15/2025.
- What is the rationale behind the proposed Verifactu postponement?
- The AEAT aims to achieve "maximum convergence" between Verifactu and the incoming mandatory B2B e-invoicing regime, as well as alignment with future EU digital reporting requirements under ViDA.
- What is the difference between Verifactu and mandatory B2B e-invoicing?
- Verifactu governs billing software characteristics—integrity, preservation, traceability, and immutability of invoice records. Mandatory e-invoicing governs the issuance, transmission, and receipt of invoices between trading parties.
- What should businesses do in light of the proposed Verifactu postponement?
- Businesses must continue preparing for the 2027 deadlines established by Real Decreto-ley 15/2025, as the proposed October 2028 deadline lacks legal force until formally amended in the BOE.
- What is the timeline for mandatory B2B e-invoicing in Spain?
- Mandatory B2B e-invoicing will apply to businesses with annual turnover exceeding €8 million from October 2027, and to all other businesses from October 2028.
