Verifactu in Spain: The Real 2027 Deadlines (Not 2026)

The real Verifactu deadline: 1 January 2027, not 2026

Verifactu is the working name for Spain’s Sistemas Informaticos de Facturacion (SIF) mandate: a legal requirement that invoicing software meet certified standards of integrity and traceability. Real Decreto 1007/2023 set the original framework, implementing the anti-fraud invoicing obligations already written into Ley 11/2021. The deadline attached to that framework has been delayed twice since, and the version still circulating on a lot of accounting-software marketing pages and even some advisory blogs, 1 January 2026 for companies and 1 July 2026 for autonomos, is no longer correct.

Real Decreto-ley 15/2025, in force since 4 December 2025, pushed the mandatory dates back a further year: 1 January 2027 for Impuesto sobre Sociedades (corporate tax) taxpayers, and 1 July 2027 for autonomos and other IRPF-taxed businesses and professionals covered by article 3.1. This is confirmed directly on AEAT’s own Verifactu FAQ page, last updated 22 July 2026. If you are reading a guide, a software vendor’s pitch, or an advisor’s page that states a 2026 date without qualification, treat it as outdated.

Why this matters beyond pedantry: businesses that budgeted a 2026 compliance project around the earlier dates now have an extra year they did not expect, useful breathing room if you have not started yet, but also a trap if you assumed the first delay, Real Decreto 254/2025’s 1 January/1 July 2026 dates, was the final word and stopped tracking the file. The deadline has already moved twice in two years. Treat 1 January 2027 and 1 July 2027 as the current best information, not as permanently fixed.

What Verifactu actually requires of your invoicing software

The SIF mandate is a technical standard before it is anything else. Whatever software issues your invoices, an off-the-shelf accounting package, a custom ERP module, or a manually maintained spreadsheet process, has to guarantee the integrity, traceability, and inalterability of every billing record. In plain terms, that means no silent edits or deletions after an invoice is issued, and a verifiable log of every invoicing event that a subsequent audit can trust.

A QR code is required on every invoice, scannable by the recipient to verify the invoice directly with AEAT. That single requirement forces a real decision for most businesses: either your current software vendor ships a certified update that generates a compliant QR and meets the integrity standard, or you need to move to software that does, well before your applicable deadline.

2026 functions in practice as a voluntary testing window. Software providers are rolling out certified versions through the year, and adopting one early lets you iron out invoicing-workflow issues, numbering sequences, QR generation, integration with your accounting or ERP system, before the mandatory date rather than during the scramble everyone else will be having right before it.

Veri*Factu vs the non-verifiable modality: which fits your business

AEAT built a genuine choice into the system, not a single fixed format. Under the Veri*Factu modality, your software transmits a structured summary of each invoice to AEAT in real time as it is issued. AEAT pre-validates the record as it is created, which meaningfully lowers your own audit burden later, since the tax authority already holds a real-time copy it trusts. Under the non-Veri*Factu modality, records are kept locally to the same integrity, traceability, and inalterability standard, but nothing is transmitted live. That shifts a heavier self-certification and internal-audit burden onto the business, since there is no real-time third-party record to point to if a dispute arises later.

Feature	Veri*Factu modality	Non-Veri*Factu modality
Transmission	Real-time summary sent to AEAT at issuance	Kept locally, not transmitted live
Audit burden	Lower, AEAT already holds a pre-validated copy	Higher, business carries the self-certification burden
Best suited to	Most small and mid-sized foreign-owned companies	Businesses with strict internal controls already in place

Most small and mid-sized foreign-owned companies benefit from Veri*Factu specifically because it reduces the audit-defense workload down the line. A business with robust internal control processes already, or specific software constraints that make real-time transmission impractical, may reasonably choose the non-verifiable path, but should budget more compliance overhead for it. We help make this call as part of a setup engagement, since it is a decision your software provider or ERP vendor also needs configured correctly, not just a legal preference to state on paper.

The deadline timeline: 2023 to now, and why it kept moving

The mandate’s history is worth knowing precisely, because the pattern (two delays in roughly two years) is itself useful information when you decide how much urgency to attach to today’s dates.

Date	Legal instrument	What changed
2023	Real Decreto 1007/2023	Original SIF/Verifactu framework established, initial target 2025
1 April 2025	Real Decreto 254/2025	First delay: pushed to 1 January 2026 (companies) and 1 July 2026 (autonomos)
4 December 2025	Real Decreto-ley 15/2025	Second delay: pushed to 1 January 2027 (companies) and 1 July 2027 (autonomos and other article 3.1 obligados)

This is now the second delay inside two years. We track AEAT’s official Verifactu FAQ page and the underlying BOE texts as part of every ongoing client relationship in this vertical, precisely because a third delay, or a narrower carve-out for a specific taxpayer category, would not be a surprising outcome given the pattern so far.

Who’s affected, and the penalties for non-compliance

The obligation attaches broadly: any business or professional issuing invoices with a Spanish tax presence falls under scope, on whichever timeline applies to their taxpayer category. Foreign ownership does not change this. A Spanish SL wholly owned by a foreign parent company has exactly the same Verifactu obligations, on exactly the same deadline, as a company owned entirely by Spanish residents, because the obligation attaches to the Spanish taxpayer entity’s own filing status (Impuesto sobre Sociedades or IRPF), not to who holds its shares.

Advisory firms tracking the reform commonly cite penalties under article 201 bis of the General Tax Law (LGT), introduced by Ley 11/2021, of roughly 50,000 EUR per fiscal year for businesses using non-compliant invoicing software, and roughly 150,000 EUR per fiscal year per system type plus 1,000 EUR per uncertified unit sold for software producers and distributors of non-compliant systems. We treat these figures as directionally correct rather than a certainty to build a decision around casually; confirming the current LGT article text against your specific situation is part of what a proper compliance review covers, not something worth guessing at from a blog post.

Exact scope questions and any narrow carve-outs for specific taxpayer categories are worth confirming directly for your business rather than assuming either way. That confirmation, plus a written answer on which deadline actually applies to your entity, is the first deliverable of our Verifactu compliance review.

What foreign-owned Spanish companies should prepare now

A practical checklist, in the order it actually needs doing:

• Confirm which deadline applies to your entity: 1 January 2027 if taxed under Impuesto sobre Sociedades, 1 July 2027 if operating as autonomo or another IRPF-taxed structure
• Ask your current invoicing or accounting software provider directly, in writing, when their Verifactu-certified version ships
• Decide between the Veri*Factu and non-Veri*Factu modality before your provider configures the system by default, not after
• Confirm QR-code generation is supported and correctly formatted across every invoice template you actually use, not only your main one
• If you operate multiple entities or branches in Spain, confirm compliance is being tracked and budgeted per taxpayer, not assumed centrally
• Build in testing time during 2026’s voluntary window rather than waiting for the mandatory date to discover a problem

If part of your Verifactu preparation involves bringing in a Spain-based finance lead or relocating key staff to manage compliance locally, our work visa Spain and Beckham Law guides cover the personal side of that move. And if you are separately weighing whether to run Spanish operations through an EOR or your own entity, or deciding between a subsidiary and a branch, our EOR vs entity Spain and subsidiary vs branch guides sit alongside this one in our wider corporate services for foreign companies hub.