The invoicing timetable for businesses and professionals is changing once again. On 5 October, two related but distinct developments took place, and it is important to distinguish between them.
- On the one hand, the timetable for implementing mandatory B2B e-invoicing between businesses and professionals is now official.
- On the other, the Spanish Ministry of Finance has announced its intention to postpone the outstanding requirements relating to invoicing software systems, commonly known as VERI*FACTU, until October 2028.
However, this second change still needs to be incorporated into the legislation. As of 5 October 2026, the new VERI*FACTU dates have not yet been published in the Spanish Official State Gazette (BOE).
Below, LEIALTA explains what is changing and what companies should review.
B2B e-invoicing now has an official timetable
The main regulatory development on 5 October was the publication of Order HAC/1028/2026, which regulates the technical and functional elements of the public electronic invoicing solution.
This Order enters into force on 6 October 2026, officially starting the countdown established under Royal Decree 238/2026.
The mandatory B2B e-invoicing requirement will be introduced in stages:
- 6 October 2027: businesses and professionals whose volume of transactions exceeded €8 million during the previous calendar year.
- 6 October 2028: all other businesses and professionals falling within the scope of the rules.
As a rule, mandatory B2B e-invoicing will apply to transactions where there is an obligation to issue an invoice and the recipient is a business or professional with its registered office, permanent establishment, domicile or habitual residence in Spain, under the terms established by the legislation.
This requirement may therefore also be relevant for international groups, subsidiaries and permanent establishments operating in Spain.
The Ministry of Finance announces that VERI*FACTU will also be postponed until October 2028
Alongside the publication of the Order, the Ministry of Finance has announced its intention to amend the timetable under the Regulation governing invoicing software systems once again.
According to the information released on 5 October, the outstanding requirements under Royal Decree 1007/2023 will be postponed until October 2028. The aim is to align them with the general implementation of mandatory B2B e-invoicing for businesses and professionals with a volume of transactions of €8 million or less.
Until now, the official timetable required invoicing software systems to be adapted:
- before 1 January 2027 for Corporate Income Tax taxpayers;
- before 1 July 2027 for all other businesses and professionals covered by the Regulation.
These dates are still the ones currently set out in the published legislation.
It is therefore important to distinguish between the announcement made by the Ministry of Finance and its formal incorporation into the legal framework. The new October 2028 deadline will need to be reflected in the corresponding regulatory amendment before it can be considered legally definitive.
At LEIALTA, we will continue monitoring the official publication and will update the timetable once the change has been formally approved. Subscribe to our alerts service by clicking here to stay up to date.
VERI*FACTU and mandatory B2B e-invoicing are not the same requirement
The decision to coordinate the two timetables may raise an obvious question: are VERI*FACTU and mandatory B2B e-invoicing the same thing?
No. Although both affect invoicing processes, they regulate different aspects.
The Regulation on invoicing software systems establishes how the software used to issue invoices must operate. Among other requirements, these systems must guarantee the integrity, preservation, accessibility, legibility, traceability and unalterability of invoicing records.
Within this framework is the VERI*FACTU system, under which invoicing records are automatically sent to the Spanish Tax Agency.
B2B e-invoicing, by contrast, regulates how invoices must be issued, transmitted and received electronically between businesses and professionals falling within its scope.
They are therefore two separate requirements that may affect the same company’s invoicing system at the same time. What the Ministry of Finance now intends to do is coordinate their implementation to reduce duplication and avoid requiring companies to make several technological adaptations within a short period.
What should companies review now?
The announcement of a further postponement of VERI*FACTU does not mean that companies should stop all their adaptation projects.
The publication of Order HAC/1028/2026 does represent a definitive regulatory step for mandatory B2B e-invoicing. Companies should therefore consider:
- Identifying which companies or activities within the group fall within its scope.
- Checking the volume of transactions that will determine the applicable implementation date.
- Reviewing current invoice issuance and receipt systems and processes.
- Coordinating the adaptation with software providers.
- Avoiding isolated changes without considering how the two frameworks will ultimately operate together.
Companies with a volume of transactions above €8 million face a particularly close deadline: mandatory B2B e-invoicing will apply to them from 6 October 2027.
For VERI*FACTU, however, it will be necessary to monitor the regulatory developments before treating October 2028 as a legally definitive date.
A timetable moving towards coordinated implementation
The publication of this new legislation resolves one of the main uncertainties surrounding mandatory B2B e-invoicing and gives companies specific dates with which they can now work.
At the same time, the announcement concerning VERI*FACTU points towards a change in approach: coordinating the different digital invoicing requirements to avoid successive adaptations of companies’ systems.
The additional time should not be interpreted as a halt to the digitalisation process. On the contrary, it gives companies more time to review together the systems, procedures and obligations that will affect them.
At LEIALTA, we analyse the tax and accounting implications of regulatory changes and support Spanish and international companies in reviewing their obligations in Spain.
We will continue monitoring the regulatory amendment that formalises the new timetable for invoicing software systems and will update this information once official confirmation is available.
