The Ministry of Finance Announces That the Pending VERI*FACTU Obligations Are to Be Postponed to October 2028, but the Postponement Is a Forecast, Not Yet Law
On 5 October 2026 the Spanish Ministry of Finance (Gabinete de Prensa) published an informational note forecasting that the obligations still pending under Royal Decree 1007/2023, the regulation on computerized invoicing systems that includes VERI*FACTU, will be postponed until October 2028. The stated purpose is to align the calendar with mandatory B2B e-invoicing for businesses and professionals with annual turnover of up to EUR 8 million, which the tax administration has fixed at 6 October 2028. The note describes a plan, not an adopted rule, and until a legal instrument is approved the dates in Royal Decree-law 15/2025 remain the ones in force.
Background
Royal Decree 1007/2023 regulates the computerized invoicing systems (SIF) used to issue invoices in Spain and creates the VERI*FACTU option, under which each invoice record is sent to the tax administration (AEAT) at the time of issue. The adaptation deadline has already been moved once. Royal Decree-law 15/2025 of 2 December 2025 set the dates that the AEAT still publishes: software must be adapted before 1 January 2027 for taxpayers that file Corporate Income Tax and before 1 July 2027 for all other taxpayers.
In parallel, Royal Decree 238/2026 of 25 March 2026 and Order HAC/1028/2026 of 2 October 2026 set up mandatory B2B e-invoicing. KGT reported on 8 October 2026 that the Order entered into force on 6 October 2026 and that the obligation applies from 6 October 2027 for businesses above EUR 8 million and from 6 October 2028 for all others. Businesses and software vendors have therefore been facing two overlapping programs with different dates.
The Legislative Change
There is no legislative change yet. The Ministry note is a statement of intent: it forecasts a change to the deadlines of the pending obligations under Royal Decree 1007/2023 and does not name the legal instrument that will carry it. The AEAT notice on the extension of the adaptation period, which the AEAT website shows as updated on 7 October 2026, still cites Royal Decree-law 15/2025 and the dates of 1 January 2027 and 1 July 2027.
The note describes a two-step sequence. First, the calendars of the two regimes would be aligned, with the pending obligations under Royal Decree 1007/2023 moving to October 2028. Second, once that alignment is approved, a further amendment would converge the scope and certain technical aspects of VERI*FACTU and e-invoicing, taking into account the digital reporting requirements that will follow from ViDA. The note adds that the requirements on integrity, retention, accessibility, legibility, traceability and inalterability, and the other technical safeguards, are to remain substantially equivalent to those in the current regulation.
Scope
The note refers to the pending obligations for businesses and professionals and ties the October 2028 date to the date on which e-invoicing becomes mandatory for those with annual turnover of up to EUR 8 million. It does not state whether the postponement also covers taxpayers that file Corporate Income Tax, whose current deadline is 1 January 2027, and it does not mention a different date for them. Some press reports mention an earlier date of January 2028 for that group; no official text read by KGT contains it, and it should not be relied on.
Timeline
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2 December 2025 — Royal Decree-law 15/2025 sets 1 January 2027 (Corporate Income Tax filers) and 1 July 2027 (all others) for adapting invoicing software.
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5 October 2026 — Ministry of Finance note forecasts postponement of the pending obligations to October 2028.
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6 October 2026 — Order HAC/1028/2026 enters into force; the B2B e-invoicing periods begin.
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6 October 2027 and 6 October 2028 — B2B e-invoicing applies to businesses above and up to EUR 8 million of turnover respectively, as published by the AEAT.
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October 2028 — forecast new date for the pending VERI*FACTU obligations; not yet in force.
Businesses Affected
Every business and professional that issues invoices in Spain through a computerized invoicing system, and every software vendor and ERP team that supplies or operates one. Multinational groups with Spanish entities are affected in two ways: the SIF adaptation work planned for 2027 may move, and the group will need to coordinate it with the e-invoicing program that is now running from 6 October 2026.
Required Actions
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Do not stop work on the basis of the note. Until a legal instrument is published, plan against 1 January 2027 and 1 July 2027, which are the dates the AEAT website still shows.
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Re-sequence the program so that, if the postponement is confirmed, the VERI*FACTU or SIF work and the e-invoicing work can be delivered as one change on the invoice output and transmission design.
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Check with software vendors and platform providers what they will support, and on what dates, because a vendor may keep its original release plan.
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Where VERI*FACTU test records are already being sent, read the AEAT notice: during the testing period taxpayers may stop sending test records and may use another invoicing system until their deadline, and those who opt in during the period should check the AEAT FAQ on whether they must stay in the system until the end of the calendar year.
Practical Implications
The most useful reading of the note is that Spain intends to avoid two separate invoicing programs landing on small and medium-sized businesses within a year of each other. For SAP-based groups it suggests that the invoice record, the faithful copy of the invoice and the status messages that Order HAC/1028/2026 requires may eventually be designed together. That is an inference from the note and not something the note says.
The risk is a planning gap. A postponement that is announced but not enacted can lead teams to pause work that is still legally due on 1 January 2027 or 1 July 2027. Until the instrument is published, the prudent position is to keep the current dates as the baseline and treat October 2028 as the upside scenario.
Expected Next Steps
A legal instrument approving the calendar alignment, which the note does not name or date, followed by the later amendment on scope and technical convergence. The AEAT pages should be updated when that happens; at the time of writing they still show the dates of Royal Decree-law 15/2025. KGT will report when the instrument is published.
How Can KGT Support You?
KGT is a specialist indirect tax technology firm. We implement and run SAP Document and Reporting Compliance (SAP DRC) and deliver SAP-integrated e-invoicing add-ons where DRC does not yet cover a requirement or where a transformation programme makes a DRC rollout impractical in the available window. Our work is done inside the SAP landscape rather than around it, so VAT determination, document creation, transmission, status handling and reconciliation stay in one place.
For Spain KGT can map your invoicing systems against Royal Decree 1007/2023, Royal Decree 238/2026 and Order HAC/1028/2026, set out a combined plan that holds up under both the current and the postponed calendar, and build and test the SAP-integrated invoice record, faithful copy and status interfaces.
This update is for information only and is not tax or legal advice. Please consult your tax adviser before acting on it.
