Verifactu delayed to October 2028: what to do if your invoicing software is custom-built
Yesterday, 5 October, Spain's tax agency (Hacienda) announced that Verifactu won't be mandatory until October 2028. For weeks the question on my phone had been "what do I do about my software?", and today it became "so there's no rush anymore?". My short answer: you gain time, but less than it looks like.
In short
- New date: October 2028, the same for companies and self-employed.
- Reason: to make it coincide with mandatory B2B e-invoicing.
- Status: for now it's an announcement. It still has to be written into a regulation.
- Requirements: they stay, though there may be technical adjustments.
- If your software is custom-built: adapting it is on you. There's no vendor to do it for you.
What has changed
The obligation moves from 2027 to October 2028, for everyone at once. And it's not the first time it has been postponed.
| Who | Previous date | New date (announced) |
|---|---|---|
| Companies | 1 January 2027 | October 2028 |
| Self-employed and other taxpayers | 1 July 2027 | October 2028 |
The reason is to coordinate it with mandatory e-invoicing between businesses. The order that launches it was published on 5 October and came into force on the 6th. Companies with turnover under €8 million have 24 months to adapt, that is, October 2028: the same date.
One important caveat: for now this is only an announcement. The change still has to be published in a regulation, and some media already say 6 October 2028 specifically. Until it's published, I'd treat it as "very likely", not "signed".
Why it affects you more if your software is custom-built
If you use commercial software, adapting it is the vendor's job: you pay the fee and wait for the update. But if your software was written by a developer or your own team, the adaptation is yours, and nobody is going to call to remind you.
In the Verifactu mode, the software has to meet four requirements at once:
- Keep a record of every invoice that can't be modified or deleted.
- Chain each record to the previous one, so any tampering is detectable.
- Include a QR code on every invoice.
- Send the records to the tax agency.
There is another mode without automatic submission, but it asks for additional requirements: electronically signing each record and keeping them to hand over if Hacienda requests them.
And mind what's at stake: Spain's General Tax Law provides fines of €50,000 per year for using non-compliant software.
On top of that comes e-invoicing. Your software will have to issue and receive invoices in a structured electronic format. Hacienda has put forward technical adjustments so both obligations fit together, also because of the EU's ViDA rules. In other words, these aren't two independent adaptations: it's better to think of them together.
What I recommend you do now
Use the delay to prepare, not to forget about it.
- Find out where your software stands. Who maintains it, whether you have the source code, and whether there's documentation. It sounds obvious, but it's where I find the most surprises.
- Run a diagnosis. What's missing compared with the four requirements above.
- Do the part that won't change. Records that can't be deleted, sequential numbering and an audit trail of changes. You'll be asked for those no matter what, and the work won't be wasted.
- Wait for the regulation on what can still change. Formats, submission to Hacienda and integration with e-invoicing.
- Run the numbers. Adapt your software or move to a commercial one that's already adapted. Sometimes the first pays off and sometimes the second; I wrote about how to decide in custom software vs. off-the-shelf programs.
- Aim for 2027, not September 2028. As the date approaches, developers will be swamped, and that's not just a figure of speech.
Mistakes to avoid
- "It always gets delayed, I'll deal with it later." The obligation will arrive, and it will coincide with e-invoicing.
- Paying now for a full adaptation of what may still change. That's wasted money if the formats change afterwards.
- Assuming your software can be adapted. If whoever built it is gone and you don't have the code, the problem is much bigger.
- Waiting for your accountant to warn you. They know the regulation, but they don't know your software.
Does your company invoice with custom software?
If you don't know where it stands, tell me about your case. I'll review your software, tell you what's missing and whether it's worth adapting or replacing, even if the answer is that replacing it is better.
Article updated on 6 October 2026. I'll update it when the change is published in the BOE (Spain's official gazette).
Sources
- Hacienda retrasa Verifactu hasta 2028 para alinearlo con la factura electrónica, Infobae, 5 October 2026.
- Hacienda vuelve a retrasar Verifactu y da a empresas y autónomos hasta octubre de 2028, Xataka, 5 October 2026.
- Hacienda retrasa VeriFactu hasta 2028 y lo vincula a la factura electrónica, Barnadiario.
- Verifactu obligatorio en 2027: guía de fechas, MuyPymes, 7 September 2026.