What Verifactu is, and who it covers

The short answer

Verifactu is the regulation that says what the program you issue invoices with has to look like. It is not an invoice format, it does not oblige you to send anything, and it does not change what you hand your customer¹.

It covers you if you carry on a business and invoice with a computerised system. And it gives you one of two dates: 1 January 2027 if you pay corporation tax, 1 July 2027 otherwise ².

If you have read elsewhere that the date is in 2026, whoever wrote that was not careless: it was true until December 2025.

The dates have moved twice, and the last time was December 2025

The fourth final provision of Royal Decree 1007/2023 has been rewritten twice since it was published, and each version says something different:

The version that governs is the third². And it is worth saying why it stands rather than being one of those December measures that collapses in January: Royal Decree-Law 15/2025 was ratified by an agreement of the Congress, published by resolution of 11 December 2025 ². There is an unusual legal detail in it that explains why this is still called «Royal Decree 1007/2023»: its second final provision is a safeguard of rank, so an act with the force of law amended a regulation and expressly left it its regulatory rank.

Who is covered: the system first, the tax second

Article 3.1 opens with a condition rather than a list. It applies to taxpayers «who use computerised invoicing systems, even if they only use them for part of their activity» ¹. That is the first surprise: there is no threshold. Nowhere in the regulation is there a figure for turnover, headcount or invoice count. What decides it is whether you invoice with a program.

Only then does it split by tax, across four letters:

A Spanish limited company and a sole trader doing exactly the same work are six months apart, and the only thing deciding it is the legal form².

Inside letter a) there is a finer split that almost nobody mentions. Entities fully exempt under article 9.1 of the Corporation Tax Act fall outside the regulation; the partly exempt ones in paragraphs 2, 3 and 4 of the same article are covered, but «exclusively for the operations generating income that is subject to and not exempt from the tax»¹. So an association can be covered only for part of what it invoices.

The way out the regulation leaves open

Article 3.3 says the regulation «shall not apply to taxpayers who keep the record books under the terms of paragraph 6 of article 62» of the VAT regulation¹. That paragraph is the immediate supply of information, the SII.

And it is worth reading in full, because it has two paragraphs. The first binds anyone whose VAT period is the calendar month. The second lets anybody else choose to keep them that way ⁵. So it is not merely a consequence of being a large company: it is a door a small company can open by its own decision in order to leave Verifactu's scope.

It is the same pattern that already appears on two of our pages: being inside one system takes you out of another. A company in the SII files form 303 monthly, form 111 quarterly, does not file form 347, does not file form 390 and falls outside Verifactu. Five forms, five different answers.

Your supplier's deadline has passed, and yours has not

This is the part that decides what to do today, and it is on none of the pages selling software.

The fourth final provision does not give one date, it gives three. To the taxpayers in article 3.2, who are «the producers and marketers» of the systems, it gives «nine months from the entry into force of the ministerial order» that develops the regulation¹. That order is HAC/1177/2024, and its sole final provision brought it into force the day after publication in the official gazette³. It was published on 28 October 2024, so it came into force on the 29th and the nine months expired on 29 July 2025.

And that paragraph did not move. Royal Decree-Law 15/2025 rewrote the article 3.1 dates and left the vendor's clock hanging from the order, where it was².

So today the position is this: the program you invoice with should already comply with the regulation, and has had to for more than a year, while you are not yet obliged to anything. What is called for is therefore not buying. It is asking.

Article 13 puts the burden on the producer, who must «certify, by means of a declaración responsable, that the computerised system complies» with the regulation. Paragraph 2 requires it in writing «and visibly within the computerised system itself, in each of its versions», and paragraph 3 expressly lets the customer request it¹. It is free, it is a document, and it should already exist.

The two routes, and the one that looks worse is the good one

Article 7 offers two options: your own computerised system meeting the regulation, or the application the tax administration may develop¹. And on the first, article 16 defines a category: a system that additionally sends «continuously, securely, correctly, completely, automatically, consecutively, instantaneously and reliably» all the records to the tax agency is a «verifiable invoice issuing system», or VERI*FACTU¹.

Sending is voluntary. What almost nobody mentions is what you get in exchange:

The system that sends everything to the tax agency has fewer technical requirements than the one that keeps the records in-house. Article 16.2 presumes it meets the article 8 requirements by design and excludes it from article 14.2; article 16.3 tells it that it has no obligation to sign the records electronically, «it being sufficient that they calculate the hash of those records» ¹. Declining to send is not the light way out: it is the heavy one.

One detail worth knowing before starting: there is no registration form. Article 16.5 says the option is understood to be taken «by the act of systematically starting to send», and that it «shall run at least until the end of the calendar year» of the first submission¹. You join by beginning, and you cannot leave until the year ends.

And a note for anyone who thinks declining keeps them disconnected from the administration: article 8.1 requires that every system, sending or not, «must have the capacity to send the records to the tax administration by electronic means»¹. The capacity is compulsory either way; using it is what is optional.

The big penalty is not yours

Article 201 bis of the General Tax Act dates from 2021, two years before the regulation that gives it content, and it splits into two very unequal tiers⁴:

The 150,000 EUR falls on whoever builds or sells, and it multiplies by two magnitudes at once: by each trading year in which sales occurred and by each distinct type of system⁴. Two years and three products is 900,000 EUR.

The end user faces 50,000 EUR per year, and here there is a nuance the pages quoting that figure to frighten you tend not to make. Paragraph 2 does not penalise any non-compliant system: it penalises holding those that «are not duly certified where a regulation requires them to be», or certified devices that have been altered⁴. And Royal Decree 1007/2023 established no certification regime: it chose the producer's declaración responsable instead¹. Whether that condition is met is an arguable reading, and we are not going to settle it here: the sensible course is to ask before taking the larger figure as given.

What is certain: neither allows the 30 % agreement reduction, because article 188.1 reserves it to articles 191 to 197. Only the 40 % early-payment reduction of article 188.3 reaches them ⁷. And the second paragraph of paragraph 2 prevents double punishment: anyone already penalised under paragraph 1 cannot also be penalised under paragraph 2⁴.

It is not compulsory e-invoicing

This is the commonest confusion on the subject, and it has an identifiable cause we will come to. They are two different obligations:

That last row is the one that matters. The eighth final provision of Ley 18/2022 fixes no date for article 12. Its effects run «one year after the approval of the implementing regulation» for anyone invoicing more than eight million euros and «two years after» for everyone else, and it adds that «the entry into force of article 12 is subject to obtaining the EU derogation from articles 218 and 232 of Directive 2006/112/EC»⁶.

Those are two suspensive conditions and neither is a day on the calendar. So any page printing a date for B2B e-invoicing is printing something the legal text does not contain. We are not saying here what state either condition is in, because that changes and we have not verified it: we are saying how the mechanism works, which anyone can read in the gazette in a minute.

So why are the two confused so often? Because the e-invoicing act itself points at the Verifactu regulation. Paragraph 6 of article 2 bis of Ley 56/2007, as rewritten by Ley 18/2022, says that systems managing invoicing «must respect the requirements referred to in article 29.2.j) of Ley 58/2003», which is exactly the provision Verifactu hangs from⁶. They are linked; they are not the same.

A worked example with real numbers

A Spanish limited company in Valencia invoices with a management program, is not in the SII and has its tax domicile in common territory.

It is covered by article 3.1.a), because it pays corporation tax, so its date is 1 January 2027. If the same business were run by a sole trader, it would be covered by letter b) and would have until 1 July 2027: six months more, on the strength of the legal form alone.

In both cases the program's supplier was obliged to offer it fully adapted by 29 July 2025. So what needs doing in September 2026 is not buying anything: it is asking them for the declaración responsable of article 13 and checking which route the program implements. If it sends the records, the company saves itself the electronic signature and its own event log, and is presumed compliant by design.

And if that company chose to join the SII voluntarily under the second paragraph of article 62.6 of the VAT regulation, it would leave Verifactu's scope entirely, at the cost of taking on the immediate supply of information.

You can check your own case, your date and the comparison of the two routes in the Verifactu checker.