Verifactu: 2027 deadlines, the 2028 announcement and penalties

The legal dates for Verifactu currently in force are 1 January 2027 for corporate income tax payers and 1 July 2027 for everyone else. On 5 October 2026 a postponement to October 2028 was announced, but it is not published in the BOE (Spain's official gazette): until it is, the 2027 dates apply.

Last reviewed: 2 November 2026. Announced, pending publication; until it appears in the BOE, the 2027 dates apply. This guide will be updated once a rule is published.

Calendar in force

Milestone	Date	Rule
Regulation on computerised invoicing systems ("Veri*Factu Regulation")	Approved in 2023	Royal Decree 1007/2023
Anti-fraud legal framework	2021	Law 11/2021
Current obligation dates	1 January 2027 (corporate income tax payers) and 1 July 2027 (others: self-employed under personal income tax, entities under income attribution...)	Royal Decree-law 15/2025, published in the BOE on 3 December 2025 and validated on 11 December 2025

The regulation and dates are explained from an Odoo point of view in the complete guide. Software vendors have their own calendar, separate from users': the postponement being discussed affects users.

The announced postponement to 2028

On 5 October 2026 the Ministry of Finance announced its intention to postpone the Verifactu obligations to October 2028, to align them with mandatory B2B electronic invoicing. Three points are worth keeping in mind:

1. It is an announcement, not a rule. As of this review it is not published in the BOE.
2. In the meantime, the legal dates are the 2027 ones. An announced intention does not change what is binding.
3. It may change. The final text, if published, could differ from what was announced. This guide is reviewed when there is news.

Given this uncertainty our advice is practical: do not wait for the postponement to be published before you start, because the inventory, testing and training work is the same; only the margin you have changes.

Who it applies to and who is excluded

It applies to businesses and professionals who use a computer system to invoice in Spain's common tax territory, the Canary Islands (where references to VAT are read as IGIC), Ceuta and Melilla.

Excluded:

• Taxpayers who keep their books through the SII (Immediate Supply of Information).
• Taxpayers of the Basque Country (TicketBAI / Batuz) and Navarre (own regime) when they are taxed there.

For the Canary Islands nuances, see Verifactu in the Canary Islands with IGIC and Odoo. In mixed cases, your tax advisor should confirm.

Penalties

Article 201 bis of the General Tax Law, introduced by Law 11/2021, provides:

Who	Penalty provided
Users of non-compliant systems	Up to 50,000 euros per year
Producers or sellers of non-compliant systems	Up to 150,000 euros per year and type of system

These are maximum amounts that the rule provides for, not an automatic figure. What matters for a business is that liability is not limited to the vendor: the user of a non-compliant system can also be penalised. That is why you should know which solution you use and what guarantees its producer gives, including the responsible declaration. There is no AEAT certification for software.

What to do now, whatever the date

1. Find out whether it applies to you: SII, foral territory, Canary Islands.
2. Inventory your invoicing system: version, edition, modules, point of sale and customisations. If you use Odoo, see the table by version.
3. Choose a solution and ask for the producer's responsible declaration.
4. Test on a copy with the AEAT test environment.
5. Obtain or renew the digital certificate you will need.
6. Train the invoicing team and define what to do on rejections or outages.
7. Set a go-live date with margin, avoiding closing periods.

Doing this now is not alarmism: it spreads work that, if left to the end, gets compressed into a few weeks.

Planning with two scenarios

Because the postponement is not yet a rule, the sensible approach is to work with two scenarios at once and decide at each milestone which one applies.

	Scenario A: the 2027 dates stand	Scenario B: the postponement to October 2028 is published
What happens	Obligation on 1 January or 1 July 2027, depending on your case.	Dates shift; the final text will specify how.
What you do	Close inventory, solution and testing with margin before the date.	Keep the plan, but with more time to test and train.
Main risk	Arriving untested and without a partner available.	Relaxing and bunching all the work at the end.

The advice is common to both: start with what is never wasted, which is the inventory of your system and the analysis of whether it applies to you.

What is still unclear

It is worth being honest about the open questions while no text is published:

• Exact form and scope of the postponement. The intention and the October 2028 date were announced, but not the text of the rule.
• Whether it will affect all obliged taxpayers equally. We will not know until it is published.
• Which calendar will apply to software vendors. They have their own, separate from users'.

We do not fill those gaps with guesses. Once a rule is published, this guide will be updated with its BOE reference.

Where to follow developments

To avoid relying on third-party summaries, use primary sources:

1. The BOE, where any rule changing the dates is published. Look for Royal Decree-law 15/2025 and provisions amending it.
2. The Spanish Tax Agency's e-office, which publishes official information on Verifactu and the test environment.
3. Your tax advisor, who confirms how each change affects your specific case.

Can we help?

uKodeIT reviews your situation without pressure and proposes a realistic plan for the date that applies to you. See the Verifactu for Odoo service page or contact us.