Verifactu and e-invoicing guide for small businesses (Spain)

Verifactu and mandatory e-invoicing are often mixed up, but they are two different rules with two calendars. This guide separates what the BOE (Spain's official gazette) says about each, which dates stand at 10 October 2026 and what the Ministry of Finance has announced without having approved it yet.

Reviewed on 2026-10-10. BAI Business offers an invoicing solution and publishes this article. This is not tax advice: confirm your case with your adviser.

Two different rules

	Verifactu (computerised invoicing systems)	Mandatory e-invoicing
Rule	Royal Decree 1007/2023	Royal Decree 238/2026
What it regulates	How the program that generates invoices must work: integrity, retention, accessibility, legibility, traceability and inalterability of the records	The electronic format in which businesses and professionals issue, send and receive invoices between themselves
Who complies	Taxpayers of Corporate Income Tax, of personal income tax (IRPF) with economic activities, of Non-Resident Income Tax with a permanent establishment and entities under the income attribution regime with activity	Businesses and professionals, with a calendar according to their volume of operations
How the deadline is counted	Fixed dates set by the BOE	From the entry into force of a ministerial order

Sources: Royal Decree 1007/2023 and Royal Decree 238/2026, accessed on 2026-10-10.

Verifactu: what it requires

The regulation governs how computerised invoicing systems must work to guarantee the integrity, retention, accessibility, legibility, traceability and inalterability of invoicing records, so that any alteration leaves a note (source: Spanish Tax Agency, general questions, accessed on 2026-10-10).

Two points that get confused:

• There is no single way to comply. The Tax Agency describes two valid modes: VERIFACTU, in which the records are sent to the Agency, and NO VERIFACTU, in which they are kept in the system itself and sent if the authorities request them. In addition, for anyone who issues few invoices and has no program of their own, the Agency makes a free application available on its online portal.
• Invoices carry a QR code. Once the regulation is enforceable, all invoices, whether complete or simplified, must include a QR code; in VERI*FACTU mode it can also carry the legend "verifiable invoice" (same source).

Who it applies to

Article 3 of Royal Decree 1007/2023 includes taxpayers of Corporate Income Tax (point a), of personal income tax carrying out economic activities (b), of Non-Resident Income Tax with a permanent establishment (c) and entities under the income attribution regime with economic activity (d). Entities fully exempt from Corporate Income Tax and those who keep their record books under the terms of paragraph 6 of Article 62 of the VAT Regulation are left out. It also reaches those who produce and market invoicing programs (source: BOE, accessed on 2026-10-10).

The dates stated in the BOE

Royal Decree-Law 15/2025, published in BOE no. 290 of 3 December 2025, amended the fourth final provision of Royal Decree 1007/2023. According to its text, those obliged under Article 3.1.a) must have their systems adapted "before 1 January 2027", and the rest of those obliged under Article 3.1 must have them operational "before 1 July 2027" (source: BOE, accessed on 2026-10-10).

The Tax Agency explains it like this: the period before those dates is a testing period, during which you may stop sending test records with a system in VERI*FACTU mode and use other systems to invoice, until the deadline for having the systems adapted (source: Tax Agency information note, accessed on 2026-10-10).

What the Ministry of Finance has announced and is not approved

On 5 October 2026, the Ministry of Finance published an information note in which it plans to postpone the pending obligations of Royal Decree 1007/2023 until October 2028, to make them coincide with the mandatory e-invoicing of the businesses and professionals whose annual turnover does not exceed 8 million euros. The note adds that an amendment focused on the convergence of scope and technical aspects will follow, and that the requirements of integrity, retention, accessibility, legibility, traceability and inalterability will be maintained in substantially equivalent terms (source: Ministry of Finance, accessed on 2026-10-10).

What we know and what we don't, at 10 October 2026:

• Stated: the Ministry's announcement, linked from the Tax Agency's Verifactu page, which on that same date still shows the information note with the 2027 dates.
• Not stated: a rule published in the BOE that changes the dates. We haven't found one; we have not reviewed the BOE after this date.
• What it means for you: until it is published, the dates in force are those of Royal Decree-Law 15/2025. This guide will be updated when the amendment is published.

Mandatory e-invoicing between businesses

Royal Decree 238/2026 of 25 March develops the system of mandatory e-invoicing between businesses and professionals. It was published in BOE no. 79 of 31 March 2026 and came into force on 20 April 2026, but its effective application is deferred: it is counted from the entry into force of a ministerial order on the public e-invoicing solution (source: BOE, accessed on 2026-10-10).

That order is Order HAC/1028/2026 of 2 October, published in the BOE on 5 October and in force since 6 October 2026. The Tax Agency summarises the deadlines counted from that date:

Deadline	Date	Who and what
12 months	2027-10-06	Businesses and professionals with a volume of operations above 8 million euros: issue, send and receive e-invoices and report invoice statuses and payments
24 months	2028-10-06	All other businesses and professionals: issue, send and receive e-invoices; legal persons with a volume of up to 8 million euros must also report invoice statuses and payments
36 months	2029-10-06	Natural persons and entities under the income attribution regime: report invoice statuses and payments

Source: Tax Agency, 7 October 2026, accessed on 2026-10-10.

The Ministry's note of 5 October explains precisely that the planned postponement of Verifactu to October 2028 aims to align both calendars with the mandatory e-invoicing of businesses and professionals whose annual turnover does not exceed 8 million euros, which according to the table above arrives on 2028-10-06.

What to do now

With the uncertainty over the dates, the prudent course is what works in any scenario. These are our recommendations, not a legal obligation:

1. Find out whether it applies to you. Check whether you pay Corporate Income Tax or IRPF with activity and whether you fall under any exception in Article 3. If in doubt, ask your adviser.
2. Ask your invoicing provider. Which mode it offers (VERIFACTU or NO VERIFACTU), whether it already complies with the regulation and when it will activate it. The infringement of producing, marketing or holding systems that do not meet the specifications is set out in Article 201 bis of the General Tax Law, according to the Tax Agency's own page.
3. If you invoice in a spreadsheet or a text document, decide in good time whether to move to an invoicing program, instead of waiting for the last quarter.
4. If you issue few invoices, consider the Tax Agency's free application.
5. Review this guide when any change of dates is published in the BOE.

Where BAI fits in

According to the sheet for its invoicing solution, in BAI Business each invoice comes out of the customer's record, numbered; with Verifactu active it carries its QR code and its record is sent to the Tax Agency. The sheet does not state which mode of the regulation it uses or that it covers the e-invoicing between businesses of Royal Decree 238/2026. You can see it on the invoicing and payments page.

Frequently asked questions

Is Verifactu the same as mandatory e-invoicing?

No. Verifactu comes from Royal Decree 1007/2023 and regulates how the programs that generate invoices must work, so that they cannot be altered without leaving a trace. Mandatory e-invoicing between businesses and professionals comes from Royal Decree 238/2026 and regulates the format in which they are issued, sent and received. They are two rules, with two calendars.

Which date applies today to adapt my invoicing program?

According to the BOE and the Tax Agency, before 1 January 2027 for Corporate Income Tax taxpayers and before 1 July 2027 for all the others obliged. The Ministry of Finance announced on 5 October 2026 that it plans to postpone the pending obligations until October 2028, but at 10 October 2026 that amendment is not stated as approved in the BOE.

Am I obliged to send my invoices to the Tax Agency?

Not necessarily. The Tax Agency describes two valid modes: VERIFACTU, in which the records are sent to the Agency, and NO VERIFACTU, in which they are kept in the system itself and provided if the authorities ask for them. What is mandatory is that the system complies with the regulation.

Can I keep making invoices in a spreadsheet?

The regulation applies to anyone who uses computerised invoicing systems, even if they use them for only part of their activity, and requires guarantees of integrity, retention, traceability and inalterability of the records. An editable spreadsheet does not offer those guarantees on its own; check with your adviser whether your case falls under an exception in Article 3.

You may also be interested in

• How to choose a CRM for your small business: to decide which tool brings customers and invoices together.
• GDPR for small businesses: how long to keep your customers' data: retention periods for tax documentation.

Sources

• Royal Decree-Law 15/2025 of 2 December (BOE no. 290 of 3 December 2025), accessed on 10 October 2026.
• Royal Decree 1007/2023 of 5 December: Regulation on computerised invoicing systems, accessed on 10 October 2026.
• Tax Agency: Computerised Invoicing Systems (SIF) and VERI*FACTU, accessed on 10 October 2026.
• Tax Agency: information note on the extension of the SIF adaptation period, accessed on 10 October 2026.
• Tax Agency: general questions on the SIF and VERI*FACTU, accessed on 10 October 2026.
• Ministry of Finance: information note of 5 October 2026 on the planned change of deadlines, accessed on 10 October 2026.
• Royal Decree 238/2026 of 25 March on e-invoicing between businesses and professionals (BOE 31-3-2026), accessed on 10 October 2026.
• Tax Agency: Public E-Invoicing Solution (7 October 2026), accessed on 10 October 2026.