Two separate obligations, a more coordinated timetable
The Treasury has announced that Verifactu will be postponed until October 2028, with the aim of coordinating its implementation with that of mandatory e-invoicing between businesses and professionals. The change gives companies and self-employed workers more time to adapt their processes, although the announced timetable does not mean that the two obligations are equivalent or that all the details have been resolved.
Verifactu sets requirements for invoicing software, with safeguards for the integrity, retention and traceability of records, and protection against improper changes. B2B e-invoicing, by contrast, regulates the issuing and exchange of invoices in electronic format for transactions between businesses and professionals. The Treasury has proposed moving towards greater convergence between the systems, including in certain technical and implementation aspects, but this adaptation will require regulatory changes.
E-invoicing retains deadlines based on company size
The published timetables set the start of e-invoicing at October 2027 for companies with annual turnover of more than eight million euros. For companies and professionals below that threshold, the deadline is extended to October 2028. Available reports differ on the specific day in October for the first group; it is therefore advisable to distinguish the month and applicable category from the exact dates, which will have to be confirmed in the relevant regulations.
The postponement of Verifactu is intended to reduce the likelihood that businesses will have to make successive technological adjustments within a short period. However, the announced coordination does not mean that planning should be put on hold: Verifactu’s current technical requirements remain in force until the announced amendments are approved.
Positive reactions and outstanding issues
The Spanish Association of Tax Advisers (Aedaf) and the National Federation of Associations of Self-Employed Workers (ATA) had advocated coordinating the timetables. Lorenzo Amor, president of ATA, described the postponement as “the most coherent approach” for self-employed workers and argued that avoiding consecutive adaptations would reduce the operational burden of the change. These assessments reflect the organizations’ positions; they do not replace the applicable regulations.
The need for clarification also extends to sectors with particular invoicing processes. In the travel agency sector, CEAV has pointed out that changes to trips, travellers, services, prices or cancellations may require corrections if they affect invoices already issued or their records. Ana Barluenga, director of its legal department, welcomed the additional time but warned that operational questions remain.
One issue concerns the Tax Agency’s free invoicing solution: according to CEAV, it currently does not cover certain transactions linked to the Special Scheme for Travel Agencies (REAV) or some intermediary transactions. The industry association is calling for it to be adapted to these specific circumstances. Questions also remain about the final scope of the framework and the treatment of certain documents, such as those created using office software, based on issues raised by sector associations.
What businesses should bear in mind
The announcement provides more time, but leaves a transition period during which businesses will have to follow the provisions that specify how convergence will work. In particular, each business will need to distinguish between the obligations that apply to its invoicing systems and those that regulate the exchange of invoices with other businesses or professionals. The exact dates and final scope will depend on the regulations that formalize the announced changes.
Coordination is also being considered in light of the future European digital reporting requirements associated with ViDA, which are scheduled to be rolled out across the European Union from 2030. This reference helps explain part of the harmonization objective, but does not in itself change the Spanish obligations currently in force or make it possible to anticipate the final content of future rules.