Postponement of the Verifactu System

The Spanish Council of Ministers has agreed to postpone the implementation of the Verifactu system by one year, through the approval of a Royal Decree-Law modifying the originally planned timeline. As a result, the entry into force of the Verifactu Regulation will be moved to 2027, in order to provide companies, professionals, and software developers with a more gradual adaptation period.

According to the information made public by the government, the new mandatory implementation dates will be as follows:

1 January 2027 for Corporate Income Tax (IS) taxpayers.
1 July 2027 for entrepreneurs and professionals under Personal Income Tax (IRPF).

It should be noted, however, that the Royal Decree-Law has not yet been published in the Official State Gazette (BOE). Only once the official text is available will these measures become definitive. The RDL15/2025, of 2 December, which will come into force tomorrow, 4 December, and is subject to approval by Parliament within a maximum period of 30 days.

Based on the information available at this time, our recommendation is as follows (subject to review once the Royal Decree-Law is officially published, and considering that 2026 will constitute the voluntary implementation period for Verifactu):

If your company has already adapted or is close to completing the adaptation to Verifactu, we recommend continuing with the implementation plan and aiming to be ready during 2026.
This approach allows your company to benefit from the increased control, security, and process efficiency offered by the system, regardless of the new mandatory deadline.

Regarding clients who voluntarily opted to join the SII (Immediate Supply of Information) and whose voluntary inclusion has already been accepted by the tax authorities:

Since your inclusion in the SII has been validated, we will review your situation with you to determine the most appropriate next steps.

For clients who were in the process of adapting to the SII but had not yet submitted the voluntary opt-in request, you may choose to:

Discontinue your SII adaptation efforts and instead prepare your company to transition directly to Verifactu when it becomes mandatory in 2027; or
Proceed with voluntary inclusion in the SII during any taxable quarter of 2026 or 2027.

Please also note that once published, the Royal Decree-Law must subsequently be validated or repealed by the Spanish Congress, as is standard for all decree-laws.

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