Spain’s digital invoicing framework is entering a new phase. A recent informative note announces the intention to postpone the pending obligations under Royal Decree 1007/2023, which regulates the requirements applicable to invoicing software systems, until October 2028.
The stated objective is to align the timetable for the invoicing software rules commonly associated with VeriFactu with the future mandatory B2B electronic invoicing regime for SMEs, self-employed professionals and other businesses whose annual turnover does not exceed EUR 8 million.
However, there is an important legal point to bear in mind: the announced October 2028 date has not yet been incorporated into the current consolidated wording of Royal Decree 1007/2023. As of today, the regulation still formally states that Corporate Income Tax taxpayers must have their systems adapted before 1 January 2027, while the remaining affected taxpayers must do so before 1 July 2027. Therefore, October 2028 should currently be treated as the Government’s announced timetable pending the corresponding regulatory amendment and its publication in the Spanish Official Gazette.
Why is the implementation being postponed?
The main reason is to achieve greater regulatory and technical coordination between two closely related digitalisation projects: the requirements imposed on invoicing software by Royal Decree 1007/2023 and the future mandatory electronic invoicing system between businesses and professionals.
Aligning both timetables should reduce the risk of companies being required to make two major technological adaptations in a short period of time. For SMEs and self-employed professionals, this is particularly relevant, as the same accounting and invoicing systems are often expected to support both compliance frameworks.
The announced approach is also intended to facilitate future convergence with the digital reporting requirements arising from the EU VAT in the Digital Age (ViDA) initiative.
What remains unchanged?
The postponement does not mean that the underlying VeriFactu requirements are being abandoned.
The informative note expressly states that the key guarantees established by Royal Decree 1007/2023 will remain substantially equivalent. These include the integrity, conservation, accessibility, legibility, traceability and inalterability of invoicing records, together with the remaining technical safeguards required from compliant invoicing systems.
In practical terms, the objective continues to be that invoicing software should generate reliable records and prevent invoices or billing data from being deleted or altered without the corresponding traceability.
Should businesses stop preparing?
No. The postponement gives businesses additional time, but it should be used to plan the transition more efficiently rather than to disregard it.
Companies that are currently changing their ERP, billing or accounting software should still consider whether the proposed system is capable of adapting to both the VeriFactu framework and future mandatory electronic invoicing. Choosing a system with this functionality now may reduce duplicated implementation costs later.
It is also important to distinguish between businesses that use specific invoicing software and those that issue invoices using simpler tools. The application of Royal Decree 1007/2023 depends on the characteristics and functionality of the system actually used, so the position should be reviewed on a case-by-case basis.
Practical takeaway
The announced postponement until October 2028 is positive news for many SMEs and professionals, as it provides more time to prepare for the digital transformation of invoicing in Spain.
Nevertheless, businesses should continue monitoring the formal legislative amendment before treating October 2028 as the definitive legal deadline. The current regulation still contains the 2027 dates, and the final wording of the amendment will be essential to confirm the new timetable and the degree of coordination between VeriFactu, mandatory B2B electronic invoicing and future EU digital reporting obligations.
For businesses already reviewing their invoicing processes, the best approach is therefore not to stop preparing, but to use the additional time to implement the changes in an orderly and cost-efficient way.