We have previously reported in past communications on the measures approved for the digitalization of billing systems and the strengthening of control over economic transactions, which involve adapting or changing companies’ billing systems, with their implementation initially scheduled for 2026. However, as we have also communicated, the enforcement dates were subsequently extended to, in principle, take effect in 2027.
In this regard, it is worth clarifying that VERIFACTU and electronic invoicing are two distinct obligations, although both are part of the billing digitalization and control process.
At this stage, given the proximity of the new mandatory compliance dates, we consider it timely to remind you of the main obligations and, particularly the need for companies to review their billing systems and procedures well in advance. This includes electronic invoicing, which is mandatory as a document shared between businesses and professionals (commonly known as B2B).
1.VERIFACTU:
VERIFACTU originates from Law 11/2021 on the prevention of and fight against tax fraud, and its implementation through Royal Decree 1007/2023 of December 5, which sets out the requirements that billing systems and software must meet.
The regulations aim to ensure that billing records are complete, traceable, and unalterable through technical mechanisms such as record chaining and their corresponding fingerprint or hash code.
One of the options provided is VERIFACTU, through which billing records are automatically and continuously sent to the Spanish Tax Agency (AEAT).
However, the regulations also allow the use of systems that do not send records directly to the AEAT, provided they comply with the established technical requirements.
Who does it affect?
In general, it affects businesses and professionals who use computer systems to manage their billing processes, whether they bill other companies, professionals, or end consumers. Therefore, VERIFACTU is not limited to B2B transactions.
Certain legally established cases are exempt, including, as a general rule, those subject to the Immediate Supply of Information system (SII).
Adaptation Deadlines
Computer systems must be adapted to the regulations by the following dates:
- January 1, 2027: Corporate Income Taxpayers.
- July 1, 2027: Remaining businesses and professionals within the scope of the rule.
These dates were modified by Royal Decree-law 15/2025 of December 2
2.Mandatory electronic invoicing:
The second action involves the implementation of mandatory electronic invoicing between businesses and professionals (B2B), which differs from the scope of VERI*FACTU, as the latter applies both to transactions between businesses and with end consumers (B2C). This obligation stems from Law 18/2022 of September 28 on Company Creation and Growth (commonly known as the Ley Crea y Crece) and has been developed by Royal Decree 238/2026 of March 25.
The new Spanish Electronic Invoicing System will allow the use of private invoice exchange platforms as well as a public solution managed by the Spanish Tax Agency (AEAT). Furthermore, the system will provide visibility into specific invoice statuses, including their acceptance or rejection and payment information, thereby strengthening the traceability of commercial operations and payment terms.
When will electronic invoicing become mandatory?
The effective implementation of this obligation is linked to the entry into force of the corresponding ministerial order that completes the development of the public electronic invoicing solution. Once that order comes into force, the scheduled timeline is as follows:
- Companies whose turnover exceeded 8 million euros: the obligation will become enforceable 12 months later.
- Remaining businesses and professionals: the obligation will become enforceable 24 months later.
The draft ministerial order foresees its entry into force on October 1, 2026. If this date is maintained in the final text and published in those terms in the Official State Gazette (BOE), the resulting schedule would be:
- October 1, 2027: companies with a turnover exceeding 8 million euros.
- October 1, 2028: remaining businesses and professionals.
As of the date of drafting this note, the final ministerial order is pending official approval and publication; therefore, these dates must be confirmed once it is published in the BOE.
3.SUMMARY. Two obligations that should not be confused
In short:
VERIFACTU
- Regulates the billing software or computer system.
- Its main purpose is tax control and fraud prevention.
- In general, it affects businesses and professionals using billing software, both in B2B and B2C transactions.
- Systems must be adapted by January 1,2027, for companies and July 1, 2027, for the rest.
Mandatory B2B Electronic Invoicing
- Mainly regulates the format, exchange, and management of electronic invoices.
- Its purpose is to promote digitalization and reduce late payments.
- It affects transactions between businesses and professionals.
- If the entry into force of the ministerial order on October 1, 2026, is confirmed, it will be mandatory on October 1, 2027, for companies with a turnover exceeding 8 million euros, and October 1, 2028, for the rest.
Therefore, complying with VERI*FACTU does not automatically mean complying with the future obligation for B2B electronic invoicing. These are distinct obligations that may require different adaptations.
4.Recommendations
Although there are still months ahead before these obligations come into effect, we consider it advisable not to wait until the deadlines to begin the adaptation process.
We recommend:
- Reviewing the programs and systems you currently use to issue invoices.
- Alternatively, analysing the possibility of opting for the Immediate Supply of Information (SII), which would exempt you from VERI*FACTU compliance.
- Confirming with your software providers that they will be compliant with VERI*FACTU requirements.
- Analysing the potential adaptations required for future B2B electronic invoicing.
- Reviewing the integration between billing, accounting, and other management systems.
- Checking how the receipt, acceptance, rejection, accounting, and payment of electronic invoices will be managed.
- Planning the necessary technical and organizational changes well in advance.
Adaptation should not be limited to the billing software alone. It will also be necessary to review internal business procedures, particularly regarding the receipt and management of invoices and payment tracking.
The entry into force of these new obligations represents a significant change in how companies manage their billing operations.
2027 will be a particularly important year: companies must have their billing systems adapted to VERIFACTU and, for certain operators, B2B electronic invoicing is also expected to come into effect.
Therefore, we recommend reviewing currently used billing systems starting now and confirming their adaptation to the new requirements with software vendors, avoiding the need to make rushed changes as mandatory compliance dates approach.
At Marroquín Abogados, we will continue to monitor regulatory developments and the final implementation dates for these obligations.
For any clarification or advice regarding VERIFACTU, billing system adaptation, or future mandatory electronic invoicing, please do not hesitate to contact us.
