Spanish invoicing: e-invoicing deadlines are set, and VeriFactu is due to move to 2028

1. B2B e-invoicing: the deadlines are set

Order HAC/1028/2026 regulates the Agencia Tributaria's public e-invoicing solution. It was published in the BOE on 5 October 2026 and took effect the next day, which starts the countdown set by Royal Decree 238/2026. Invoices between businesses and professionals in Spain will have to be electronic.

• 6 October 2027: businesses and professionals with turnover above €8 million.
• 6 October 2028: everyone else, including the self-employed.

Invoices can go through the public solution or through a private platform, which must send a faithful copy to the public one. Businesses will also have to report the status of the invoices they receive, including payment.

2. VeriFactu: a delay to October 2028, announced

Royal Decree 1007/2023 sets requirements for the software businesses use to issue invoices. VERI*FACTU is one of the two types of system it allows: it sends a summary of each invoice to the Agencia Tributaria as it is issued. The current dates are 1 January 2027 for companies that pay Impuesto sobre Sociedades and 1 July 2027 for everyone else.

On 5 October 2026 Hacienda announced it will postpone the pending VeriFactu obligations to October 2028, to line them up with e-invoicing. It also said the technical requirements (integrity, retention, traceability and inalterability of records) will stay substantially the same.

The catch: the delay needs a change to Royal Decree 1007/2023 published in the BOE. Until then, the 2027 dates are the ones in force.

What it means for a team of 15 to 250

You will most likely adapt once, not twice: the same invoicing setup will need to issue structured e-invoices and keep VeriFactu-grade records. That makes it one project. If you invoice from a spreadsheet, a homemade tool or an old ERP, that is still the place to look first.

What to do this quarter

• Check which band you are in: above or below €8 million turnover.
• List every place your company issues an invoice: ERP, online shop, point of sale, booking system, spreadsheets.
• Ask each vendor in writing how and when it will send e-invoices, and how it handles VeriFactu.
• Plan e-invoicing and VeriFactu as one project, and watch the BOE before treating the 2028 date as final.

This is a summary, not tax advice. Check the dates and your own case with your gestor or tax adviser.