The roll-out of mandatory electronic invoicing between businesses and professionals is entering a new phase. Order HAC/1028/2026 was published on 5 October, completing the outstanding regulatory framework and setting out the timetable for the widespread adoption of B2B electronic invoicing.
At the same time, the Tax Agency has communicated, via the Forum of Tax Professionals’ Associations and Bodies, its intention to postpone until October 2028 the outstanding obligations linked to the Regulation on computerised invoicing systems, known as the VERI*FACTU system.
Two key dates for electronic invoicing
The new timetable sets out two distinct periods:
- 6 October 2027: mandatory for companies with an annual turnover exceeding 8 million euros.
- 6 October 2028: extension to all other companies, professionals and self-employed workers.
The aim is to move towards the gradual roll-out of the new electronic invoicing model and to reduce the coexistence of different regulatory timetables.
VERI*FACTU has been postponed to align with the electronic invoicing system
At the same time, the outstanding obligations arising from Royal Decree 1007/2023 are expected to be deferred until October 2028, so that their implementation coincides with the widespread adoption of electronic invoicing.
The aim is to prevent businesses and professionals from having to make successive adjustments to their invoicing systems within a short timeframe and, at the same time, to prepare the Spanish model for future European digital reporting requirements arising from ViDA.
The postponement does not, however, imply any reduction in the technical guarantees required of invoicing systems in areas such as the integrity, preservation, accessibility, legibility, traceability and immutability of records.
Fernando Matesanz, a partner at Allyon ETL, played a key role in the postponement
The decision also reflects the work carried out over recent months by AEDAF and its Expert Group on Indirect Taxes, coordinated by Fernando Matesanz, a VAT partner at Allyon ETL.
Matesanz has thus been one of the key figures directly involved in the technical drive behind this deferral, participating in the analysis of the implications of the timetable and in the drafting and submission of proposals to the authorities. The group has argued before the AEAT and other stakeholders for the need to establish a coordinated roadmap between VERI*FACTU, electronic invoicing and future European regulations, thereby avoiding successive obligations that would force companies to repeatedly modify their IT systems.
The postponement of VERI*FACTU must now be formalised through the corresponding regulatory amendment.