Invoicing in Spain: the Verifactu system postponed until 2027, providing additional time to prepare for compliance

The obligation to declare and secure invoices issued through invoicing software in Spain, known as the Verifactu system, has been postponed by one year, until 2027, by decision of the Ministry of Finance. This measure addresses the adaptation challenges faced by many companies, as highlighted by professionals in the sector.

This reform requires companies to use certified invoicing software in order to ensure compliance with the requirements of Verifactu. The postponement was announced on 2 December 2025 by the President of the Spanish Government, Pedro Sánchez, through a decree-law. This is the second delay of a reform that was initially scheduled to enter into force in 2025.

This additional timeframe gives companies and self-employed professionals valuable time to anticipate compliance and prepare in a more structured and secure manner.

Contents

1. What is Verifactu?
2. Background and reasons for the postponement
3. Implications for companies and self-employed professionals
4. New implementation timetable
   4.1. Details of priority cases (1 January 2027)
   4.2. Deferred cases (1 July 2027)
   4.3. Full exemptions from Verifactu
5. Recommended actions

1. What is Verifactu?

Verifactu is the invoice verification system established by Anti-Fraud Law 11/2021.
Its purpose is to ensure the integrity and immutability of digital accounting records and to strengthen the fight against tax fraud.

Under this framework, any invoicing software concerned, with the exception of manual invoicing, the SII system or the regional tax regimes of the Basque Country and Navarre, must generate locked records, incorporate a unique QR code and include the mention “VERI*FACTU” on each invoice. This information must be available to the Spanish Tax Agency in real time, either through direct transmission or via a secure storage system. Software compliance is confirmed through a responsible declaration submitted by software providers to the Ministry of Economy.

2. Background and reasons for the postponement

The Verifactu obligation was initially scheduled to enter into force on 1 July 2025. However, it had already been subject to a first adjustment, with implementation postponed to 1 January 2026 for companies and to July 2026 for other taxpayers, mainly due to delays in the certification of invoicing software.

The new postponement until 2027 follows repeated requests from business and self-employed associations, which warned of the lack of maturity of certain technical solutions and the risk of saturation among software providers. This decision also forms part of a broader political context, linked to the adoption of economic and budgetary measures negotiated at parliamentary level.

3. Implications for companies and self-employed professionals

All companies and self-employed professionals using invoicing software, whether point-of-sale systems or ERP solutions such as Sage or Contaplus, will be required to migrate to Verifactu-certified versions. Failure to do so may result in penalties of up to €300 per non-compliant invoice, capped at €50,000 per non-prescribed financial year.

Beyond its mandatory nature, the system also offers several advantages. It helps reduce VAT fraud, simplifies tax audits and enhances the security of accounting data through encryption and time-stamping mechanisms, thereby limiting the risk of disputes or challenges.

The main costs to anticipate relate to software updates, staff training and the implementation of secure cloud-based storage solutions.

4. New implementation timetable

The application of Verifactu is now structured around two main phases, depending on the type of tax entity, while taking into account the specific characteristics of the Spanish economic landscape. The first group, affected from 1 January 2027, includes individuals and legal entities subject to Corporate Income Tax with an annual turnover below six million euros. The second group, applicable from 1 July 2027, covers entities exceeding this threshold, as well as those subject to specific tax regimes.

These adjustments make it possible to adapt the Verifactu obligation to the diversity of existing structures, particularly with regard to self-employed professionals, partially exempt entities and simplified regimes.

4.1. Details of priority cases (1 January 2027)

Entities included in this first phase must comply as a priority, as they represent the majority of affected small and medium-sized enterprises.

These mainly include legal entities subject to Corporate Income Tax with an annual turnover below six million euros, as well as partially exempt entities, solely in respect of transactions generating taxable income.

This scope covers approximately 90% of invoicing software users.

4.2. Deferred cases (1 July 2027)

An additional deadline is granted to larger structures or those with specific characteristics.

This includes entities subject to Corporate Income Tax with an annual turnover equal to or exceeding six million euros, self-employed professionals subject to Personal Income Tax who carry out an economic activity, as well as certain special regimes, particularly in the agricultural and livestock sectors.

The territories of the Canary Islands, Ceuta and Melilla also benefit from specific adaptations reflecting their particular tax regimes.

4.3. Full exemptions from the Verifactu system

Certain taxpayers are fully excluded from the Verifactu obligation, regardless of the implementation timetable. This is notably the case for users of the SII system, for whom the immediate supply of invoice data to the Tax Agency makes Verifactu redundant.

Taxpayers relying exclusively on manual invoicing, those subject to the regional tax regimes of the Basque Country and Navarre, as well as certain VAT-exempt transactions or activities subject to lump-sum assessment regimes, are also excluded.

5. Recommended actions

It is essential to accurately identify your tax regime and specific situation in order to determine the applicable implementation deadline. If you are subject to the SII system, no further action is required.

In other cases, analysing turnover, tax status and the nature of the activities carried out will help clarify the obligations that apply. In mixed situations, where activities subject to Corporate Income Tax and Personal Income Tax coexist, the obligation applies only to the taxable activities concerned.

Anticipating the entry into force of Verifactu not only helps avoid non-compliance risks, but also provides an opportunity to optimise invoicing processes. Our firm provides tailored accounting support to help you secure this transition and approach the 2027 deadline with confidence.

Miguel Morillon

Lawyer

MORILLON AVOCATS