1. New Start Dates and Government Decision
1.1 Corporate taxpayers: 1 January 2027
The obligation for companies within the corporate income tax perimeter now begins on 1 January 2027 after a one-year deferral.
1.2 SMEs and self-employed: 1 July 2027
Small businesses and autónomos switch on 1 July 2027, also one year later than originally planned.
1.3 Legal instrument and status
The postponement was approved by the Council of Ministers on 2 December 2025 through a royal decree-law aimed at easing the transition to digital invoicing controls.
2. What Verifactu Requires from Software
Verifactu sets technical rules for billing systems used by businesses and professionals. Compliant software must produce standardized invoice records and guarantee authenticity, integrity, traceability, and accessibility so that manipulations leave an auditable trail. The regime governs how invoices are generated and preserved; it does not change the underlying VAT rules.
3. Who Falls Within Scope and When
Two groups enter on different dates. Corporates lead in January 2027. SMEs and self-employed follow in July 2027. Guidance from the tax administration distinguishes between certified “Verifactu” operation and an alternative mode on the issuer’s own approved system; additional carve-outs or special treatments will be clarified in follow-on instructions.
4. Compliance Workflow in Practice
Businesses must issue invoices using compliant software, create standardized records at issuance, protect those records against tampering, and keep them available for inspection. Verification elements such as a QR or unique reference enable immediate checks. Multi-company and multi-site setups must keep numbering, users, and devices under tight control.
5. Sanctions and Enforcement
Non-compliant systems or the use of uncertified software can trigger fines up to €50,000 per financial year. Separate penalties may apply to vendors that market non-compliant tools. The size of these sanctions makes early testing and documentation essential.
6. Adoption Status and Market Readiness
Survey data cited in late 2025 shows roughly 8% of SMEs and autónomos had implemented Verifactu-ready tools and 15% were mid-implementation. Low readiness is a key reason for the 2027 runway; the extra time should be spent stabilizing software and proving audit trails.
7. Preparation Priorities for 2026
7.1 Software Conformity
Confirm your vendor’s Verifactu alignment, update contracts, and lock a release calendar for fixes.
7.2 Data Discipline
Tighten master data (legal names, NIF, series, tax treatment) and validate totals at issuance.
7.3 Traceability and Retrieval
Operate protected event logs, preserve original records, and rehearse retrieval for inspections.
8. Key Milestones
2 Dec 2025: Government confirms one-year deferral via royal decree-law.
1 Jan 2027: Go-live for corporate taxpayers.
1 Jul 2027: Go-live for SMEs and self-employed.
