There are two different obligations and most articles mix them up. Verifactu is legally set for 1 January 2027 for companies and 1 July 2027 for the self-employed, but Hacienda has announced a postponement to October 2028 that is not in the BOE yet. B2B electronic invoicing now has a countdown: its order came into force on 6 October 2026, so businesses above €8 million have until October 2027 and everyone else until October 2028.
What you need to do now is the first one: make sure your invoicing software is certified. Holding non-compliant software carries a €50,000 penalty per year.
They are not alternatives. Eventually both apply to you.
Verifactu governs the system you issue from. From your date, every invoice has to come out of certified software that produces an unalterable record and a QR code on the invoice.
1 January 2027 for companies. 1 July 2027 for the self-employed. Before those dates, using a compliant system is voluntary.
There are two ways a system can comply. In VERI*FACTU mode, each invoice record is sent to the tax agency as it is issued. In the other mode, records stay on your system but have to be signed, chained and kept available for inspection.
What this affects: invoicing software. A spreadsheet or Word file stays outside it while you only enter data, issue, print and store. If a macro generates your VAT or income tax books, it does not.
And the part people get wrong: there is no official list of approved software. Compliance works through a responsible declaration signed by whoever produces the system. "Approved by the AEAT" on a marketing page means nothing. Ask for the document.
This is the other obligation, and it is about format, not generation. Instead of sending a PDF, you send a structured electronic invoice that the recipient's system can read.
It comes from Ley 18/2022, known as Crea y Crece, and was developed by Royal Decree 238/2026, published on 31 March 2026.
Its timetable is staged, and this is the detail almost nobody reports correctly:
That order is Orden HAC/1028/2026. It was published on 5 October 2026 and came into force the next day. From then, the periods run: 12 months for businesses with turnover above €8 million, 24 months for everyone else.
Two transitional rules worth knowing. For the first 12 months, large businesses have to send a readable PDF alongside the electronic invoice unless the recipient accepts the original format. And reporting payment status stays voluntary for businesses under €8 million for their first 12 months.
Practical reading for a freelancer: the obligation starts on 6 October 2028.
The content rules have not changed. A full invoice still needs:
From your Verifactu date, the QR code is added to that list.
If you apply a VAT exemption you have to say why, citing the article or stating that the operation is exempt. Putting zero is not enough.
Check your software's responsible declaration. Not the marketing claim. The signed document. If your vendor cannot produce it, you have a problem with a deadline attached.
Ask which mode it uses. VERI*FACTU mode sends records in real time. The alternative keeps them on your side with stricter obligations on you.
Check whether you can export. Including from the tax agency's own free application, where you cannot.
Sort your numbering before the switch. Gaps in a series are among the first things looked at, and migrating software mid-year is where they appear.
Do not wait for 2027. Voluntary adoption is allowed now, and switching in the last quarter alongside everyone else is how people end up non-compliant on day one.
Set by article 201 bis of the Ley General Tributaria, and both are classed as serious.
€50,000 per year for holding systems that do not meet the requirements, when they should be certified and are not, or when a certified system has been altered.
€150,000 per year for manufacturing, producing or marketing non-compliant systems, per financial year with sales and per distinct type of system.
The second one falls on the vendor, not on you. The first one falls on you, which is why the responsible declaration is worth asking for in writing.
Mixing up the two obligations. The most common of all, and the reason wrong dates circulate.
Assuming a PDF is an electronic invoice. A PDF sent by email is a digital copy, not a structured electronic invoice.
Waiting for an official list of approved software. There is not going to be one.
Thinking it only applies above a turnover threshold. Verifactu does not work that way. If you issue invoices with software, it applies.
Assuming your gestoría has handled it. The obligation to issue through a valid system is yours.
If your current tool has a published responsible declaration, no. If it does not, you have until your date to move.
Free options exist, including the tax agency's own application, which has no invoice limit but cannot issue simplified invoices and does not let you export. They are compared in free billing software.
If you also need the tool to keep your books, that is a different question, covered in accounting software for the self-employed.
Verifactu is the one with a real date. 1 January 2027 for companies, 1 July 2027 for the self-employed.
B2B electronic invoicing has dates: October 2027 above €8 million, October 2028 for everyone else.
The single action that matters now: get your software's responsible declaration, or change software.
What it costs to ignore: €50,000 per year for holding a non-compliant system.
What not to do: believe a specific date for B2B e-invoicing, or wait for an approved software list that does not exist.
In law, Verifactu applies to the self-employed from 1 July 2027, with a postponement to October 2028 announced. B2B electronic invoicing applies to them from October 2028.
No. A PDF is a digital copy. An electronic invoice is a structured file the recipient's system can process automatically.
Yes, if you only enter data, issue, print and store the invoices. No, if a macro generates your VAT or income tax books: then it counts as invoicing software and has to comply with Verifactu.
Ask for the responsible declaration. Compliant vendors publish it. "Adapting soon" is a no.
€50,000 per year for holding it. Producing or selling it carries €150,000 per year.
Verifactu applies to how you issue, whoever the client is. B2B electronic invoicing applies to invoices between businesses and professionals.
Related: Verifactu entry into force / Free billing software / Accounting software for the self-employed
