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Fiscal, 09/10/26

New deadlines for VeriFactu and electronic invoicing.


 

As you may recall, the implementation of the new obligations relating to computerized invoicing systems (SIF / VERI*FACTU), initially planned for 2026, was postponed for one year.

On October 5th, Order HAC/1028/2026 was published, establishing the deadlines for the mandatory implementation of electronic invoicing. Coinciding with this publication, and with the aim of aligning both timelines, the Tax Agency has announced a further postponement of the obligations related to SIF/VERI*FACTU, the application of which will now be delayed until October 2028.

Below, we summarize the new calendar and the main dates you should keep in mind.

When will electronic invoicing become mandatory?

With the entry into force of Order HAC/1028/2026, the mandatory B2B electronic invoice will be applicable from October 6, 2027 for businesses and professionals whose turnover in the previous year exceeds 8 million euros, and from October 6, 2028 for the rest.

From those dates, businesses and professionals must issue and receive invoices for their B2B transactions, that is, those carried out between businesses and professionals. This obligation does not affect invoices issued to private clients or end consumers (B2C).

It will no longer be enough to simply generate an invoice in Word, Excel, or PDF and send it by email. The invoice must be issued in a structured electronic and transmitted through a private electronic invoicing platform or via the free public solution that the Tax Agency will provide.

Simplified invoices (such as tickets) are generally exempt from this obligation, except in certain cases where they include the recipient's identification data and allow the exercise of certain tax rights.

The new system also establishes obligations to report certain invoice statuses, such as acceptance or rejection and actual payment, including the corresponding dates. This information must generally be reported within a maximum of four calendar days, excluding Saturdays, Sundays, and national holidays, from the date the corresponding status occurs.

During the first twelve months of the obligation's application, businesses and professionals whose turnover has exceeded 8 million euros must accompany the electronic invoices they issue with a document in PDF format that ensures their legibility, unless the recipient voluntarily and expressly agrees to receive them in their original format.

And what about VERI*FACTU?

According to the newly announced schedule, the implementation of the SIF/VERI*FACTU obligations will be postponed until October 2028.From that date, electronic invoicing systems may operate under two modalities:

  • VERI*FACTU: Billing records are automatically sent to the Tax Agency. Invoices will include the mention “VERI*FACTU” or “Invoice verifiable on the AEAT electronic portal”.
  • NO VERI*FACTU: records are not automatically sent to the Tax Agency, so the system must meet additional requirements to guarantee their integrity, traceability and preservation, including the electronic signature of the records and the keeping of an Event Log.

Invoices issued through these systems will include a QR code. However, in the case of electronic invoices, it will not be necessary to include the graphical representation of the QR code, which can be replaced by its content.

All programs must be certified and accompanied by a declaration of responsibility issued by the manufacturer.

However, certain businesses and professionals will be exempt from this obligation, including:

  • Those covered by the Immediate Supply of Information (SII).
  • Those who invoice manually using paper forms, without using a computerized invoicing system.
  • Those who use Word or Excel only to enter invoice data, issue, print and store them, without performing other billing processes using these tools.
  • Entities fully exempt from Corporation Tax.
  • Companies with respect to operations carried out from permanent establishments located abroad, without this exclusion extending to the rest of their operations.

What should be done now?

The new timeline provides more time to adapt billing systems and procedures. However, we recommend verifying that your billing software is compatible with both B2B e-invoicing and SIF/VERI*FACTU requirements , and requesting the manufacturer's declaration of responsibility .

 

You can contact this professional office for any questions or clarifications you may have.

Warm regards,

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