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Mandatory e-invoicing: the two dates that affect you

Verifactu and business-to-business e-invoicing get muddled up all the time and they aren't the same thing. What each rule says, what date each has, and what's worth doing now.

If you invoice in Spain, you'll have been warned about two things, both urgently: that you have to move to e-invoicing and that you have to make your invoicing software comply with Verifactu. They are two separate obligations, born of two separate laws. And they don't fall due on the same day.

The one with a firm date is Verifactu: if your business is a company, before 1 January 2027; if you're self-employed, before 1 July 2027. Mandatory e-invoicing between businesses still has no date in force. Its regulation was published in March 2026, but the clock doesn't start until a ministerial order comes out which, as of 27 August 2026, still hasn't. There is a draft of that order, and further down we tell you which dates it points to.

Two laws almost everybody mixes up

The confusion isn't your fault: both talk about invoices and the same salesperson sells you both. But they regulate different things.

How they differ Verifactu Business-to-business e-invoicing
What it regulates The software you make your invoices with. The format of the file and how it's sent.
Which law it comes from Anti-Fraud Act (Act 11/2021) Crea y Crece Act (Act 18/2022)
Its regulation Royal Decree 1007/2023 Royal Decree 238/2026
What it requires of you That your software logs each invoice chained to the previous one, and that nobody can delete or change it afterwards without leaving a trace. That the invoice travels as a structured file (Facturae-type: the customer's computer reads it on its own, with nobody typing anything) and that payment status is reported.
Which invoices it covers Every one you issue, including those to private individuals. Only those you issue to another business or another self-employed person.
What date it has Companies, before 1 January 2027. Self-employed, before 1 July 2027. None in force. The clock doesn't start until a ministerial order is published which, as of 27 August 2026, still hasn't appeared.

The table scrolls sideways.

Verifactu: this one does have a date

Verifactu requires your invoicing software to meet certain technical requirements. If your software comes from a well-known vendor, the work is theirs and an update will reach you. If you invoice with a spreadsheet or a Word template, that's where it catches you: that can't be adapted, it has to be replaced. If that's where you are, it's exactly what we do in e-invoicing for businesses.

A nuance that's badly sold: sending invoices to the tax authority in real time is voluntary. There are two routes. In VERI*FACTU mode the software sends each record to the tax agency as you issue it; in the other, nothing is sent, but you're required to have a chained hash and an electronic signature. Anyone telling you that you must send everything in real time is telling you half the rule.

The current dates were set by Royal Decree-Law 15/2025 of 2 December:

  • Companies (corporate income tax payers): systems compliant before 1 January 2027.
  • Everyone else, self-employed included: before 1 July 2027.

These aren't the original dates, nor the first delay. RD 1007/2023 set a single date for everyone, 1 July 2025. Royal Decree 254/2025 split it in two, January and July 2026, and the December 2025 decree-law added another year.

No hype: the fact that it's been postponed twice doesn't mean there'll be a third. It means there's no need to buy anything in a hurry, and that the useful question isn't “when is it?” but “will my software comply, and is it going to cost me more?”.

Invoicing between businesses: regulation yes, date no

Royal Decree 238/2026 of 25 March was published in Spain's official gazette on 31 March 2026 and implements the mandatory e-invoicing system between businesses and professionals. It looks like everything has been said, but it hasn't.

The regulation itself postpones its own application: twelve months for anyone who invoiced more than eight million the previous year and twenty-four for everyone else, counted not from its publication but “from the entry into force of the ministerial order” that will set the technical detail. As of 27 August 2026, that order hasn't been published.

The regulation is here. The order that starts the clock, not yet.

What there is, is a draft. The draft ministerial order went out for public consultation on 17 April 2026 and sets its entry into force at 1 October 2026. If approved as it stands: 1 October 2027 for anyone invoicing more than eight million and 1 October 2028 for the rest. It may change, and that entry into force is already tight: it's the best available clue, not a date.

There is a safety net. The tax agency will have to offer a free public solution, available at least two months before the rule first takes effect. Since that first application is the one for large companies, a small business will have it in front of them more than a year before their own turn.

Invoicing public bodies is a different matter: mandatory since January 2015 under Act 25/2013, which covers companies and other entities but leaves out sole traders who are individuals. Each authority may also exclude invoices of up to €5,000.

How the panic deflated, in one chart

The difference between a real emergency and a calendar one shows up in how many people search for the topic. These are the monthly searches for “verifactu” in Spain.

246.000 33.100 3 Dec 2025: the government postpones Verifactu to 2027. 22.200 14.800 Aug Oct Dec Feb Apr Jun 2025 2026

Monthly searches for “verifactu” in Spain, from August 2025 to July 2026. Google Ads planner estimates, pulled through DataForSEO on 27 August 2026. These are aggregated planner figures, not measurements.

The peak was December 2025, with 246,000 searches, right when the obligation was due to start in January. That same month the postponement was published, and in January searches fell to 22,200. A 91% drop from one month to the next. It has been flat at around 14,800 ever since.

What moved was the date, and the urgency with it. It's fair to expect it to climb again as 2027 approaches, and the sales offers with it.

What applies to you, depending on what you are

  • Self-employed invoicing private individuals. Verifactu only, before 1 July 2027. Business-to-business e-invoicing doesn't reach those invoices.
  • Self-employed individual invoicing other businesses. Both. Verifactu on 1 July 2027; the other, twenty-four months from the order's entry into force. If your small business is a company —an SL, most commonly— your Verifactu date isn't this one: it's 1 January 2027, the next bullet.
  • A company. Verifactu before 1 January 2027. And if you invoiced more than eight million the previous year —the threshold goes by turnover, not legal form— your e-invoicing deadline drops to twelve months.
  • If you invoice public bodies. As a company it's already been mandatory since 2015; as a self-employed individual that law doesn't oblige you, although many authorities only accept invoices that way.

What to do now without overspending

  • Ask your software provider in writing. Whether the software will be Verifactu-compliant and whether that changes the price. In writing, so you can compare and, if need be, complain.
  • If you invoice in Excel or Word, start there. It's the only case where a change is certain, and better done calmly than in June 2027.
  • Don't sign long contracts out of fear of a date that isn't even in force yet.
  • The software is half of it; the process is the other half. If the delivery note gets copied by hand onto the invoice and the invoice by hand into the bank, changing software won't fix that: it's fixed by automating the process, and there are examples in the automations any small business can use today.
  • Keep an eye on the official gazette. The ministerial order is the real starting gun.

What nobody should be selling you

A firm date for business-to-business e-invoicing. Anyone telling you “it comes into force in January” is guessing: not even the draft order has been approved.

An obligation to send everything to the tax authority in real time. That's one of Verifactu's two routes, and you choose it.

A fine that isn't yours. The penalty regime is in article 201 bis of Spain's General Tax Act, and it doesn't say the same thing for whoever makes the software as for whoever uses it: €150,000 per financial year for the maker, €50,000 for anyone running uncertified systems. If they show you the big number, that's the maker's.

A separate “Verifactu certificate”. There's no seal for you to buy: it's the software maker who certifies their program through a declaration of conformity, which must also be visible inside the system itself.

No hype: checked on 27 August 2026. The day the order appears in the official gazette, every calculation in this article changes, and we'll update it. Last reviewed: 27 August 2026.

This is general information, not tax advice. The deadlines depend on your legal form and your turnover; check your specific case with your adviser before making decisions.

Frequently asked questions

When will e-invoicing become mandatory in Spain?

Between businesses there is still no date in force. Royal Decree 238/2026 has been published, but its deadlines (twelve months for anyone invoicing more than eight million euros and twenty-four for everyone else) only start counting from the entry into force of a ministerial order which, as of 27 August 2026, has not been published. The draft of that order, out for public consultation since 17 April 2026, sets its entry into force at 1 October 2026: if approved as it stands, the obligation would land on 1 October 2027 for large companies and 1 October 2028 for the rest.

When does Verifactu become mandatory?

Corporate income tax payers must have their systems compliant before 1 January 2027, and all other taxpayers covered, self-employed people included, before 1 July 2027. Those are the dates set by Royal Decree-Law 15/2025. This is already the second postponement: Royal Decree 1007/2023 set 1 July 2025 for everyone and Royal Decree 254/2025 split it into January and July 2026.

Who is required to use e-invoicing?

The business-to-business obligation covers businesses and professionals when the recipient is another business or professional with a registered office or permanent establishment in Spain. Invoices to private individuals, ordinary simplified invoices and invoices to companies with no office or permanent establishment in Spain are outside it. Verifactu, by contrast, applies to the software you issue any invoice with, including those to private individuals.

What's the difference between Verifactu and mandatory e-invoicing?

Verifactu regulates the software: it requires invoicing records to be chained and tamper-proof, and comes from Spain's Anti-Fraud Act. Business-to-business e-invoicing regulates the format and the sending: it requires a structured file instead of a PDF and reporting of payment status, and comes from the Crea y Crece Act. They are different rules, with different regulations and different calendars.

Am I obliged to send my invoices to the tax authority in real time?

No. Sending is voluntary and you choose. In VERI*FACTU mode the software sends each record to the tax agency at the moment of issue; in the non-sending mode, the software has to guarantee a chained hash and an electronic signature. Both routes comply.

What happens if my business doesn't use e-invoicing?

Until the ministerial order is published and your deadline falls due, you're breaching nothing by invoicing other businesses in PDF. What is worth looking at now is Verifactu, because its date is fixed and it affects the software you use today. If you invoice public bodies as a company and still don't issue e-invoices, that is a breach right now.

Shall we look at it together?

We look at what you invoice with today, whether it will do for 2027 and what can be handled on its own. Without changing your software if the one you have is fine.

GV
Written by The Gran Vía Solutions team

An SEO, web and applied-AI agency in Albacete, Spain. We explain what we do in plain language, with no hype and no buzzwords.