As we already analysed in our article dated October 4th 2024, entitled “Delay in the Implementation of Electronic Invoicing in Spain”, the process of implementing the new mandatory digital invoicing systems was far from progressing in accordance with the timetable initially announced by the legislator. At that time, we highlighted the lack of regulatory development and the resulting legal uncertainty this generated for companies and professionals, who would eventually be subject to the obligation.
Recently, a further postponement has occurred in the entry into force of the electronic invoicing system.
Specifically, the Government has delayed the entry into force of Royal Decree 1007/2023 of December 5th, also known as the “Verifactu Regulation”, which constitutes the main regulatory framework governing the electronic invoicing system in Spain and sets out the requirements that invoicing software systems used by SMEs and self-employed professionals must meet.
The confirmed extension: new dates for entry into force
Initially, the regulations provided that the Verifactu system would become enforceable on a staggered basis throughout 2026: from January 1st for entities subject to Corporate Income Tax, and from July 1st for other professionals.
However, the legislator’s inaction and delay in approving the necessary implementing regulations prior to the scheduled dates has made a proper and orderly implementation impossible, both for software providers and for the companies and professionals subject to the obligation. As a result, the Government has recently approved, by way of urgency, an extension of these deadlines through Royal Decree-Law 15/2025 of December 2nd (hereinafter, the “New Decree”).
This New Decree amends the entry-into-force timetable, extending the originally established deadlines in order to allow for a more gradual technical adaptation of invoicing systems and to avoid uneven implementation among the various obligated parties. The new dates for entry into force are as follows:
- Companies subject to Corporate Tax: must have their invoicing systems adapted to Verifactu requirements by January 1st
- Other companies and self-employed professionals: will have an additional six-month period, until July 1st 2027.
This is yet another extension, confirming an increasingly common trend: announcing structural tax reforms without sufficiently realistic time planning.
Verifactu: what is postponed and what remains unchanged
It should be emphasized that this extension does not alter the substance of the obligations, but only their enforceability. Once Verifactu becomes fully mandatory, invoicing systems must ensure the integrity, traceability, and preservation of records, incorporating, among other elements:
- Identification of the invoicing software or system
- Generation of a digital fingerprint (hash) for each invoice.
- In the case of paper invoices, inclusion of a QR code or identifier enabling verification by the Spanish Tax Agency.
The objective remains unchanged: to strengthen tax control through technological tools. However, the manner in which its implementation is being managed raises reasonable concerns.
Reactions and consequences of this new extension
The decision has been met with mixed feelings. On the one hand, some business organizations and associations of self-employed professionals welcome the additional time to adapt. On the other hand, many economic operators, tax advisors, and software developers have expressed concern over last-minute changes in criteria.
In this regard, many companies prioritized the adaptation of their invoicing systems during 2024 and 2025, allocating significant financial and human resources. For them, this new delay does not represent relief, but rather a disruption to planning and resource allocation, as well as a loss of confidence in the stability of the regulatory framework.
Final considerations
The implementation of electronic invoicing and systems such as Verifactu is undoubtedly irreversible and reflects a clear European trend toward the digitalization of tax control. However, the succession of delays, extensions, and regulations pending further development is turning this process into a paradigmatic example of legal uncertainty.
Far from justifying a passive approach, this new postponement should serve as an opportunity for companies and professionals to anticipate future requirements, review their internal systems, and maintain ongoing dialogue with their technology providers. Because if one thing seems clear, it is that while the timetable may continue to shift, the obligation will ultimately arrive.
Julio González
Vilá Abogados
For more information, please contact va@vila.es
9th of January 2026
