The publication of the Order governing the public e-invoicing solution, together with the announcement that the VERI*FACTU timetable will be aligned, marks the start of a period in which the two regimes will converge. Businesses now have more time, but they still need to make early, coordinated decisions about systems, processes, controls and data quality.
Order HAC/1028/2026 develops the public electronic invoicing solution, while the Spanish Tax Agency intends to align VERI*FACTU with this timetable and with developments at European level. However, the announcement has yet to be formally enacted, so it must be distinguished from the timetable currently in force.
The deferral does not reduce the scale or importance of the work. Businesses will need to adapt ERP systems, applications, processes, master data and internal controls. Starting early will help avoid rushed decisions, operational disruption and duplicated investment.
1. VERI*FACTU and B2B electronic invoicing: related, but different
Although they are often used as if they were equivalent, B2B electronic invoicing and VERI*FACTU pursue different objectives and entail different obligations.
| B2B electronic invoicing | VERI*FACTU / RRSIF | |
|---|---|---|
|
Purpose |
To digitalise invoice exchange between businesses and professionals and facilitate monitoring of invoice status and payment. |
To ensure that invoicing systems generate complete, traceable, accessible and unalterable records. |
|
What it regulates |
The issue, transmission and receipt of structured electronic invoices, together with interoperability between platforms. |
The operation of invoicing software and the generation, retention or submission of invoicing records. |
|
Transactions |
B2B relationships within the scope of the Crea y Crece Law. |
Full and simplified invoices issued through an IT system by taxpayers within its scope. |
|
Visible element |
Invoice in a structured electronic format and status communications. |
A QR code on invoices and, where the verifiable mode is used, the wording VERI*FACTU. |
|
Practical point |
It regulates how an invoice is transmitted and processed. |
It regulates how an invoice is generated and leaves an audit trail in the system. |
These obligations may share data, formats and integrations, but they do not replace one another. A business may fall outside the RRSIF because it uses the Immediate Supply of Information system (SII) and still be affected by B2B electronic invoicing. Likewise, VERI*FACTU also applies to B2C invoices issued through IT systems where the issuer is within scope.
2. What has changed recently and the timetable currently in force
The public electronic invoicing solution
Order HAC/1028/2026, published on 5 October 2026, regulates the public electronic invoicing solution provided for in Royal Decree 238/2026. Among other functions, the platform will make it possible to issue invoices, connect private platforms, communicate invoice status and retrieve information. It also specifies aspects relating to identification, authentication, representation and the coding of invoices submitted to the public system.
Its publication completes an important part of the Spanish model. The B2B obligation will take effect in stages: first for businesses with annual turnover exceeding EUR 8 million and subsequently for all other businesses and professionals. Under the timetable arising from the Royal Decree and the Order, the reference dates are October 2027 for businesses with turnover exceeding EUR 8 million and October 2028 for all others.
The VERI*FACTU timetable
Before the Ministry of Finance announcement, the rules required mandatory adaptation of invoicing IT systems by 1 January 2027 for Corporate Income Tax payers and by 1 July 2027 for the remaining taxpayers within the scope of the RRSIF.
On 5 October 2026, the Spanish Tax Agency announced its intention to defer VERI*FACTU until October 2028 in order to align it with electronic invoicing. The announced measure will require a legislative amendment. Businesses should therefore monitor its formal enactment and avoid basing contractual or technology decisions solely on the announcement.
ViDA: 2030 and 2035 as European milestones
The European ViDA package was adopted in March 2025. Its digital reporting requirements for cross-border B2B transactions, based on electronic invoicing, will begin to apply on 1 July 2030. Subsequently, on 1 January 2035, national real-time digital reporting systems for domestic transactions will have to align with the European model and standards.
| Milestone | Reference date | Practical position |
|---|---|---|
|
B2B electronic invoicing: businesses > EUR 8m |
October 2027 |
Planned first phase following publication of the Order. |
|
B2B electronic invoicing: all other businesses in scope |
October 2028 |
Planned second phase. |
|
VERI*FACTU |
October 2028, according to the Tax Agency announcement |
Pending the legislative amendment replacing the dates of 1 January and 1 July 2027. |
|
ViDA: cross-border digital reporting |
1 July 2030 |
Transaction-by-transaction reporting based on electronic invoicing for certain cross-border B2B transactions. |
|
Convergence of national systems |
1 January 2035 |
Alignment of domestic national digital reporting systems with EU standards. |
A NOTE ON THE TIMETABLE
Electronic invoicing has a defined statutory timetable. The new VERI*FACTU timetable has been announced, but it still needs to be enacted in published legislation. This distinction should be maintained in external communications and project plans.
VERI*FACTU and ViDA share several underlying principles, but they have different scopes and implementation dates. Businesses therefore need to understand how the two regimes will interact and reflect that in their technology and compliance plans.
3. Who is affected and which businesses should start acting now
B2B e-invoicing will apply broadly to commercial transactions between businesses and professionals, subject to the detailed rules and exclusions in the legislation.
As a general rule, VERI*FACTU applies to businesses and professionals established in the Spanish common tax territory that issue invoices through an IT system and are not excluded. In practical terms, four questions should be reviewed:
- Whether invoices are issued through an IT system;
- Whether the entity is mandatorily or voluntarily registered for the SII;
- Whether the regional tax rules of the Basque Country or Navarre apply;
- Whether there is a specific decision confirming non-application.
Organisations with complex ERP systems, bespoke developments, multiple sites or invoicing channels, high transaction volumes, self-billing, third-party invoicing, customer or supplier portals, intra-Community transactions or several entities in the same group should begin their assessment now. Businesses planning an ERP upgrade or a new invoicing platform should also act early, so that e-invoicing, VERI*FACTU and ViDA requirements are built in from the outset.
Businesses using the SII are currently excluded from the RRSIF/VERI*FACTU in respect of their own invoices, but they should not therefore be left outside the project. They will still need to assess B2B electronic invoicing, consistency with the SII and future convergence with ViDA.
4. Impact on systems, processes, controls and data governance
This is not simply a software upgrade. Businesses need to understand where data comes from, how it is transformed, who validates it, which applications are involved and how incidents are managed.
- ERP systems and sales, point-of-sale, recurring invoicing or billing modules.
- POS systems, e-commerce, marketplaces and sector-specific applications.
- Electronic invoicing platforms and exchange networks.
- Accounts receivable and accounts payable tools.
- Interfaces with accounting, treasury, CRM, inventory and tax reporting.
- Document repositories, electronic archives and backups.
- Customer and supplier onboarding and maintenance;
- Invoice issue, receipt, acceptance and rejection;
- Communication of status and actual payment;
- Pre-invoicing, pro forma invoices and drafts;
- Corrective invoices, cancellations and corrections;
- Self-billing and third-party invoicing;
- Management of service outages, retries and contingency arrangements.
Controls and data governance
The tax authorities will receive information through different channels. Consistency between the invoice, invoicing record, VAT ledgers, SII, accounting records and tax returns will become increasingly important. This requires clear data owners, quality rules, periodic reconciliations, traceability of changes and correction protocols.
In particular, businesses will need to review tax fields, identifiers, series, dates, invoice types, transaction codes, taxable amounts, tax amounts, exemptions and references to corrections. Errors will leave a digital audit trail and cannot simply be resolved by overwriting the original record.
5. A practical roadmap for readiness
Identify the entities, taxes, establishments, activities and transactions affected. Distinguish between the SII, common tax territory, regional tax regimes and the specific features of the Canary Islands, Ceuta and Melilla.
Identify every point capable of issuing invoices, including local tools, proprietary developments, spreadsheets with automations, POS systems and auxiliary applications.
Document the journey from source data to the invoice, tax record, accounting entry, collection and tax reporting.
Select an electronic invoicing platform and, where appropriate, choose between VERI*FACTU and a non-verifiable system.
Compare the current model with functional, technical, tax, documentary and control requirements.
Adapt ERP systems and interfaces and review templates, series, QR codes, status messages, signatures, storage, access and contingencies.
Cover standard and exceptional scenarios, corrective invoices, cancellations, self-billing, connection outages, retries and reconciliations.
Assign responsibilities, approve procedures, train users and establish quality and incident indicators.
Ensure that current decisions do not prevent the future use of structured formats, European standards and transaction-by-transaction reporting models.
To be ready for 2027, more complex businesses should complete their assessment, solution selection and target model design during that year, leaving sufficient time for development, testing and rollout ahead of the 2028 milestones.
6. Risks of waiting and common pitfalls
- Treating the deferral as a reason to stop the project.
- Limiting the assessment to the ERP provider without reviewing satellite applications or proprietary developments.
- Confusing electronic invoicing with sending a PDF by email.
- Treating VERI*FACTU as an obligation for the tax function alone.
- Failing to distinguish scope by entity, system, invoicing centre or territory.
- Failing to review pro forma invoices, corrective invoices, cancellations and self-billing.
- Assuming that use of the SII removes every impact.
- Procuring a solution without validating interoperability, portability, service levels and future compatibility with ViDA.
- Failing to document who retains records, certificates, evidence and contingency plans.
- Deferring master-data cleansing and reconciliations until the testing phase.
A rushed implementation is likely to cost more, restrict supplier choice and allow design issues to reach production. The risk is not limited to penalties: it can also disrupt invoicing and collections, affect the customer experience and reduce the quality of financial reporting.
7. How businesses are approaching adaptation
In our client work, the usual starting point is a joint assessment involving Tax, Finance, IT and the relevant business teams. This identifies the entities and processes in scope, the systems that generate invoices and any risks around data quality or traceability.
Following that assessment, organisations are defining a target model that combines compliance and efficiency. The most common workstreams include:
- Assessment of the regulatory impact and definition of scope;
- Inventory and classification of invoicing IT systems;
- Comparative analysis of VERI*FACTU and non-verifiable modes;
- Selection and assessment of suppliers and platforms;
- Functional and tax review of ERP systems and interfaces;
- Design of controls, reconciliations and data governance;
- Definition of test cases and implementation support;
- Preparation of an architecture capable of evolving towards ViDA.
The aim is not simply to meet the compliance deadline. Businesses can use the transition to streamline processes, reduce manual effort, improve traceability and build a more reliable tax data foundation. An integrated approach also avoids treating e-invoicing, VERI*FACTU and ViDA as three separate, sequential projects.
8. Frequently asked questions
Conclusion
E-invoicing, VERI*FACTU and ViDA are part of the same shift towards tax compliance built on structured, traceable and more timely data. The revised timetable gives businesses an opportunity to manage the transition in a controlled way, but it does not remove the need to act.
Businesses that start now will have time to assess their options, align Tax, Finance and IT, improve data quality and test the chosen solution properly. Those that wait until the deadlines are close will have fewer options and a greater risk of fragmented implementation.
RECOMMENDED NEXT STEP
Carry out a scope, systems and data assessment before committing to a technology solution. The assessment should result in an implementation timetable, a decision on the operating model and a roadmap compatible with ViDA.
