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Veri*Factu: the two dates left, and why yours does not depend on your legal form

Royal Decree-law 15/2025 left the deadlines at 1 January 2027 and 1 July 2027. The line is not "companies or sole traders" but which tax you pay, and that changes the date in edge cases. There is also a third deadline, the one for software makers, which fell on 29 July 2025.

A heap of paper receipts piled on top of each other

Spain's Veri*Factu rules have been postponed so many times that many people have stopped following them. The dates currently in force are 1 January 2027 and 1 July 2027, and the criterion that decides which one applies to you is not the one most headlines repeat.

This article sets out what the consolidated text of the regulation says, with a link to each piece of legislation. We do not go into penalties and we do not give tax advice.

What Veri*Factu is

Veri*Factu is the name given to the Spanish requirement that invoicing software generate, for every invoice, an unalterable invoicing record chained to the previous one, with a cryptographic hash that makes later tampering detectable. The invoice also carries a QR code.

The rule that establishes it is Royal Decree 1007/2023, of 5 December, and the specific technical specifications sit in Order HAC/1177/2024, of 17 October, published in the official gazette on 28 October 2024.

Its stated purpose is to prevent already-issued invoices from being deleted and rewritten. It applies to the software, not to the business model: it does not require invoicing to be done differently, it requires the program used for invoicing to meet certain requirements.

The two dates

These are the ones in the consolidated text of the regulation, updated on 3 December 2025:

WhoMust have systems adapted
Corporate Income Tax payersBefore 1 January 2027
All other taxpayersBefore 1 July 2027

Here is the nuance that almost never gets explained properly. The line the regulation draws is not legal form but which tax you pay. It is constantly read as "companies in January, self-employed in July", and that translation works in the ordinary case but breaks at the edges: some unincorporated entities do not pay Corporate Income Tax, while associations and cooperatives do. If your situation is not a typical limited company or a typical sole trader, the date is determined by looking at which tax you pay, not at what the entity is called.

Why there is so much confusion about the dates

Because the calendar has moved three times, and each move produced its own round of headlines that are still circulating.

The original regulation set the requirement at 1 July 2025. Royal Decree 254/2025, of 1 April pushed it to 1 January 2026. And Royal Decree-law 15/2025, of 2 December, published on 3 December 2025 and ratified by the Spanish Congress on 11 December, moved it to the two 2027 dates in the table above.

The decree-law itself justifies its urgency on the grounds that, without it, the requirements would have become enforceable on 1 January 2026.

Verifiable or non-verifiable

The regulation allows two ways of complying, and it is worth knowing which one you are buying.

A Veri*Factu system sends invoicing records to the Spanish Tax Agency automatically as they are generated.

A non-verifiable system does not send them, and is therefore subject to stricter requirements on signing, retention and record integrity, which it must keep available to the administration.

Both are valid, and the regulation sets out different obligations for each; the exact scope of those differences is in the legislation and in the Tax Agency's own documentation. What matters when signing a contract is which of the two the product implements, because it changes where responsibility for keeping the records sits.

The deadline that already passed is not yours

There is a third date, and it is the one most often overlooked, because it does not apply to the businesses that issue invoices but to whoever makes the software.

Producers and sellers of invoicing systems had a maximum of nine months from the ministerial order coming into force to offer fully adapted products. That deadline fell on 29 July 2025.

In practice this means the part of the work that belongs to your supplier should have been done more than a year ago. If your invoicing program still cannot generate compliant records today, the problem is not a shortage of time: it is that the supplier is behind on its own obligation, and that is a conversation worth having now rather than in December 2026.

What to do now

Three concrete things, none of them urgent yet and all of them cheaper now than in a year's time:

  1. Ask your software supplier whether it already complies and from which version. In writing. It is the question that settles 90% of this for a small business.
  2. Check whether your invoicing relies on spreadsheets or hand-made documents. That is the case updating nothing will fix, because there is no program behind it that can comply.
  3. Look up the date that applies to you by tax, not by legal form, and note it with six months to spare.

At Creanimund we develop FacturIA, our own invoicing software, so we are not a neutral observer here and we would rather say so. What we stand behind regardless is the point above: asking your current supplier, in writing, is the first step and costs nothing.

Sources

This article summarises published legislation and does not constitute tax or legal advice. The deadlines have changed three times since 2023 and may change again: before making a decision, check the wording in force in the official gazette or consult your adviser.