On 5 October 2026 Spain's Ministry of Finance published a one-page note with a careful headline: a "planned change to the deadlines". It says the ministry wants to postpone everything still pending under Verifactu, the regulation that requires invoicing software to store every invoice so it cannot be deleted or edited, until October 2028. Much of the business press has reported it as settled. It is not settled yet, and the difference matters if your company invoices with its own software.
What is law today
The current timetable is the one set by Royal Decree-law 15/2025 of 2 December, which already pushed the original dates back by a year:
- 1 January 2027: companies that pay Spanish corporate income tax must invoice with a compliant system.
- 1 July 2027: everyone else, which mainly means the self-employed.
The Spanish Tax Agency still lists those two dates in its note on the extended deadline, last revised on 13 October 2026.
The penalties have not changed either. They sit in article 201 bis of the General Tax Law, added by the 2021 anti-fraud act: fifty thousand euros per financial year for anyone using non-compliant software, and one hundred and fifty thousand per year and type of system for whoever makes or sells it.
What the ministry has announced
The 5 October note says three things, and they are worth reading separately.
The first is the date. The ministry wants the pending Verifactu obligations to move to October 2028, so they land at the same time as mandatory e-invoicing for businesses with annual turnover of up to 8 million euros. The reasoning is sound: small businesses and the self-employed should change the way they invoice once, not twice in eighteen months.
The second is that technical changes are coming. Once the timetables are aligned, the ministry will work on "the convergence of the scope and certain technical aspects" of both rules, taking into account ViDA, the European Union package to digitise VAT. In other words, what Verifactu asks for today may not be exactly what it asks for in 2028.
The third is what stays. The note states that the requirements for integrity, preservation, accessibility, legibility, traceability and immutability of the records will remain "in substantially equivalent terms". The core of the system, where each invoice is chained to the previous one and cannot be touched without leaving a trace, is staying.
Why an announcement is not a deadline
A press note does not amend a royal decree. For October 2028 to become the legal date, a rule has to be published in the BOE, Spain's official gazette, and as of 23 October 2026 there is none. Until it appears, anyone who reaches 1 January 2027 with unadapted software is out of compliance, however widely the delay has been announced.
The rule will most likely arrive before the end of the year, since the ministry itself has announced it. But "most likely" is a weak foundation for a business with fifty thousand euros a year at stake.
E-invoicing does have a date
What has been published is the timetable for mandatory business-to-business e-invoicing. Royal Decree 238/2026 of 25 March regulates it, and Order HAC/1028/2026, in force since 6 October 2026, started the clock. According to the Tax Agency timetable:
- 6 October 2027: businesses whose turnover exceeded 8 million euros the previous year. During that first year, each e-invoice must come with a readable PDF.
- 6 October 2028: everyone else.
- The duty to report whether each invoice has been paid arrives in three waves: October 2027 for large businesses, October 2028 for other companies and October 2029 for the self-employed.
If your company is above 8 million, the Verifactu delay does not save you any work: a year from now you must already send and receive e-invoices.
What we would do today
If you use commercial invoicing software, ask your vendor whether it has the Verifactu responsible declaration. It is the document in which the maker certifies that the software complies, and it must be visible inside the software itself, in every version. If the vendor does not have one or does not answer, you have your answer.
If you invoice with your own or custom-built software, the problem is yours alone. The Tax Agency is unambiguous about it: if the company builds it itself, with its own staff or people it hires for the job, the company is the producer and signs the declaration. If it commissions it as a product from a third party, that third party signs. Either way someone has to adapt the software, and that is not a one-week job.
Use the extra time to do it once. If the delay is confirmed, the sensible move is to adapt your software with e-invoicing already in mind, rather than patching Verifactu now and reopening the code in 2028. The ministry has said explicitly that the two systems will converge.
Test before it is mandatory. The Tax Agency lets you start sending records through a Verifactu system voluntarily and stop again later: that is how you find the problems without penalties hanging over you.
Our experience
At Black Wings we have already integrated Verifactu into our internal ERP and tested it: it works. We mention it because most of what gets published about Verifactu summarises the regulation, and a real integration has details those summaries leave out. If your invoicing software is your own and you are not sure where to start, request the check-up and we will tell you what it is missing.
We will update this post once the delay is published in the BOE.