The modernization of tax administration in Spain reached a critical turning point in December 2025. The Ministry of Finance’s decision to postpone the entry into force of the verifiable invoicing system, technically known as Veri*factu, constitutes not merely an administrative deferral, but a strategic reconfiguration of the country’s digital roadmap. This report analyzes in depth the structural, technical, and economic implications of this measure, dissecting the new schedule that places the compliance horizon in 2027, and breaking down the complex interactions between political pressure, the technological capacity of the business fabric, and the fight against tax fraud.
- The New Schedule: Analysis of the Royal Decree and the 2027 Extension
- Technical Anatomy of Veri*factu: What Remains Unchanged
- The Principles of Inalterability and Traceability
- The QR Code and Social Verification
- The Two Modes of Compliance
- The Impact on the Software Developer Ecosystem
- Regulatory Confusion: Veri*factu vs. “Create and Grow” Law
- The Sanctioning Regime: Immediate Risks
- Sectoral and Economic Analysis
- Retail Trade and Hospitality (HORECA)
- The Professional Self-Employed
- The Role of the Digital Kit in the Transition
- Comparative Perspective: The Basque Model (TicketBAI)
- Strategic Roadmap and Conclusions
The announcement, made official following the Council of Ministers on December 2, 2025, responds to a confluence of factors that transcend purely technical issues. While the official narrative focuses on facilitating the adaptation of SMEs and freelancers, the underlying analysis reveals high-level political negotiations with parliamentary partners and a pragmatic response to the risk of a collapse in the supply of certified software.
This document aims to provide a comprehensive overview for CFOs, technology developers, tax advisors, and compliance officers, integrating the most recent data on the Anti-Fraud Law and the “Create and Grow” Law (Ley Crea y Crece) regulations.
The New Schedule: Analysis of the Royal Decree and the 2027 Extension
The modification of the implementation schedule provides tactical relief for a market that was on the verge of regulatory saturation. Until the date of the announcement, uncertainty regarding deadlines had generated considerable anxiety in the consulting and software development sectors.
Breakdown of the New Mandatory Deadlines
The Ministry of Finance has established a staggered deployment that distinguishes, more clearly than in previous drafts, the legal nature of the taxpayer. This differentiation is crucial for resource planning in companies.
Table 1: Updated Implementation Schedule for Veri*factu
| Taxpayer Segment | Previous Date (Planned/Estimated) | New Entry into Force Date (Official) | Immediate Impact |
| Corporate Income Taxpayers (S.A., S.L., and legal entities) | January 1, 2026 | January 1, 2027 | 12 months of additional margin for system auditing and ERP migration. |
| Self-Employed and Entities without Legal Personality (Individuals, Asset Communities) | July 1, 2026 | July 1, 2027 | A full one-year extension. Alignment with the 2027 Personal Income Tax (IRPF) fiscal cycle. |
| Software Developers (Ban on sale of non-adapted software) | July 29, 2025 (Original) | Subject to review (Estimated late 2026) | The commercialization and development window reopens, although the “Responsible Declaration” remains an imminent requirement for new products. |
Sources from the Ministry of Finance have confirmed that this delay seeks to offer “more time to companies, especially SMEs and the self-employed, to properly adapt to the technical demands of the new system.” However, strategic analysis suggests that the administration also required this time to ensure the robustness of its own data reception servers, avoiding scalability issues that could arise from a massive and simultaneous adoption.
The Political Economy of the Delay
It is imperative to contextualize this decision within the framework of parliamentary stability. The President of the Government, Pedro Sánchez, explicitly linked the Royal Decree-Law for postponement with the fulfillment of pending commitments to the Junts per Catalunya parliamentary group. This political dimension underscores the fragility of technical deadlines when intertwined with legislative arithmetic.
At the same time, pressure from social agents has been decisive. The National Federation of Self-Employed Workers Associations (ATA) and the CEOE (Spanish Confederation of Business Organizations) had been warning for months about the technical unfeasibility of the original deadlines. Lorenzo Amor, president of ATA, described the extension as a victory for “common sense,” arguing that the productive fabric, exhausted by inflation and bureaucratic burdens, was not in a position to assume a forced digital migration in 2026.
This convergence of political interests (need for parliamentary support) and economic reality (technical inability of the SME sector) created the perfect storm to justify a delay which, in terms of fighting fraud, means postponing the revenue expected from surfacing the underground economy.
Technical Anatomy of Veri*factu: What Remains Unchanged
Despite the change in dates, the technical requirements defined in the Regulation (Royal Decree 1007/2023) and the Ministerial Order HAC/1177/2024 remain unchanged. It is fundamental for companies to understand that the what and the how remain; only the when has changed.
The Principles of Inalterability and Traceability
The core of Veri*factu is the eradication of the principle of “creative accounting” or subsequent manipulation. Computerized Invoicing Systems (SIF) must guarantee, by design, that once an invoicing record is generated, it is immutable.
The technical mechanism to achieve this is based on the chaining of records using digital fingerprints (Hashes):
- Hash Generation: Each invoice generates a unique alphanumeric fingerprint based on its critical data (issuer, recipient, amounts, date).
- Chaining: The hash of invoice N includes in its calculation the hash of invoice N-1. This creates a cryptographic chain (similar to a private and simplified blockchain) where any modification to an old invoice would break the mathematical coherence of all subsequent invoices.
- Event Logging: The system must automatically record any interaction, error, or attempt at alteration in an event log that must also be inalterable and accessible for inspection.
The QR Code and Social Verification
A distinctive element of the Spanish regulation is the inclusion of a QR code on the graphical representation of the invoice. This element democratizes oversight: it allows any recipient (end customer or company) to scan the code and verify, through the Tax Agency’s (AEAT) electronic headquarters, whether that invoice has been declared.
If the issuer uses the Veri*factu system (immediate submission), the customer will see a message confirming that the invoice is already recorded with the Treasury. If the issuer uses the Non-Veri*factu system (local storage), the QR will facilitate the readability of the data for subsequent cross-checking, although it will not provide real-time validation of its registration with the AEAT.
The Two Modes of Compliance
The regulation offers two ways to comply with the standard, a flexibility that remains valid for 2027:
Table 2: Comparison of Compliance Modes
| Feature | “Veri*factu” Mode (Recommended) | “Non-Veri*factu” Mode (Standard) |
| Mechanism | Automatic and immediate submission of each billing record to the AEAT via web services. | Local storage of records in the taxpayer’s system. |
| Security | The AEAT acts as a trusted repository. | Requires secure retention and immediate export capability upon inspection. |
| Electronic Signature | Not mandatory for each record (identity is validated upon submission). | Mandatory for each individual billing record (advanced electronic signature). |
| Administrative Advantages | Considered to comply per se with integrity requirements. Possible automation of VAT record books. | Greater burden of responsibility in data custody and digital certificate management. |
The tax administration clearly incentivizes the submission mode (“Veri*factu”) by eliminating the complexity of electronically signing each individual invoice, shifting the burden of proof of integrity to the submission itself to the AEAT.
The Impact on the Software Developer Ecosystem
The technology sector is, paradoxically, the most affected by the uncertainty of deadlines. Software companies (ISVs) have made multimillion-euro investments to adapt their ERPs and billing systems to the original 2025 date. The delay poses challenges for cash flow and product strategy.
The “9 Months” Paradox and Commercialization
The original regulation established a prohibition on marketing non-adapted software (“dual-use software” or simply legacy software) 9 months after the approval of the Ministerial Order on technical specifications.
With the Ministerial Order approved in October 2024, the marketing deadline was theoretically set for July 2025. The delay of the obligation of use by end customers to 2027 creates a misalignment: Can developers continue selling “old” software during 2026?
Analysis of the new scenario suggests that, although the obligation of use is delayed, the obligation of offer by manufacturers will remain stricter to prevent the technological park from continuing to age. Developers must present a Responsible Declaration certifying that their software meets the requirements. This document becomes the key to market access. Manufacturers who fail to certify their products face exclusion from the market and severe penalties.
Strategies for Manufacturers Facing the Delay
Given the postponement, software manufacturers face the risk of a drop in demand in the short term, as many SMEs could postpone their purchasing decision until late 2026.
Recommended strategies for the sector include:
- Encouraging Voluntary Adoption: Selling the advantages of automation and management control beyond regulatory compliance.
- SaaS Models (Software as a Service): Migrating customers to cloud subscription models, where the update to Veri*factu is presented as a transparent continuous improvement, diluting the perception of adaptation cost.
- Early Certification: Using the “Veri*factu Ready” label as a competitive advantage against slower competitors or those maintaining legacy systems.
Regulatory Confusion: Veri*factu vs. “Create and Grow” Law
One of the biggest sources of confusion in the market, which this report must clarify decisively, is the distinction between the Veri*factu system (Anti-Fraud Law) and B2B Electronic Invoicing (“Create and Grow” Law). Although often treated as a single digitalization phenomenon, they are regulations with distinct origins, objectives, and scopes.
Structural and Purpose Differences
Table 3: Key Differences between Anti-Fraud Law and “Create and Grow” Law
| Variable | Veri*factu (Anti-Fraud Law) | Electronic Invoicing (“Create and Grow” Law) |
| Origin Regulation | Law 11/2021 on measures to prevent and combat fraud. | Law 18/2022 on business creation and growth. |
| Main Objective | Tax control. Preventing the concealment of sales (“B-Books”). | Combating commercial delinquency. Traceability of payment dates. |
| Subjective Scope | All business owners and professionals (except SII/Foral exceptions). Includes sales to end consumers (B2C) and receipts. | Exclusively operations between business owners (B2B). Does not affect invoices to end consumers (B2C). |
| Technical Requirement | Inalterable record, QR, invoice chaining. Internal record format. | Structured exchange format (XML, Facturae, EDI, UBL). Interoperability between platforms. |
| Schedule Status | Defined: January/July 2027. | Pending final approval of the Regulation. Estimated starting 2026/2027. |
The Technical Intersection: The “Hybrid Invoice”
Despite being distinct laws, they converge in practice. A company invoicing another company (B2B) will have to comply with both regulations simultaneously in the future:
- Its software must generate the inalterable record (Veri*factu) to comply with the Treasury.
- Simultaneously, it must send that invoice in a structured electronic format (“Create and Grow”) to its client to comply with commercial regulations.
The delay of Verifactu to 2027 acts as a logical “stopper.” Tax technology experts point out that it was unfeasible to implement the “Create and Grow” Law (which requires complex interoperability) without first having settled the invoice generation base (Verifactu). Therefore, it is highly probable that the “Create and Grow” Law schedule will synchronize de facto with that of Veri*factu, placing the horizon of comprehensive electronic invoicing in Spain in the 2027-2028 period.
The Sanctioning Regime: Immediate Risks
It is vitally important to communicate that the delay in the entry into force of the technical format requirements (QR, XML) does not imply a moratorium on the fight against fraud. The sanctioning regime for so-called “dual-use software” has been fully in force since October 2021.
The Prohibition of Dual-Use Software
Article 29.2.j) of the General Tax Law explicitly prohibits the possession and use of computer systems that allow:
- Keeping distinct sets of accounts.
- Not reflecting, totally or partially, the recording of transactions made.
- Recording transactions different from the annotations made.
- Altering transactions already recorded in breach of applicable regulations.
Penalties for non-compliance are severe and are not subject to the 2027 schedule:
- For Manufacturers/Marketers: A fine of 150,000 euros for each fiscal year in which software facilitating fraud has been sold.
- For Users (Companies/Self-Employed): A fine of 50,000 euros for the mere possession of these programs, regardless of whether their effective fraudulent use is proven.
Therefore, any company currently using software that allows “deleting tickets” without a trace or modifying issued invoices without generating corrective credit notes is already in a situation of extreme fiscal risk, regardless of whether Veri*factu has been delayed.
Sectoral and Economic Analysis
The impact of the delay and future implementation is not homogeneous. It affects different sectors of the economy asymmetrically.
Retail Trade and Hospitality (HORECA)
This is the sector most sensitive to Veri*factu due to the high volume of cash transactions and simplified invoices (receipts). The implementation of QR codes on every receipt involves a major operational change in POS systems. The delay to July 2027 is especially celebrated in this sector, which traditionally has tight margins and lower digitalization. However, it is also the sector under the greatest scrutiny by the AEAT for the underground economy. The extension allows these businesses to amortize their current cash registers before the mandatory investment.
The Professional Self-Employed
For professionals such as architects, lawyers, designers, or consultants, the technical impact is lower (less volume of invoices), but the administrative impact is high. Many manage their invoicing in office tools (Excel, Word). Veri*factu means the definitive end of these tools for issuing invoices. The obligation to contract SaaS software implies a new annual fixed cost. The delay gives them time to select “low-cost” tools that will predictably flood the market in 2026.
The Role of the Digital Kit in the Transition
The Kit Digital aid program is the main financial mechanism to cushion this cost. The Government has extended the deadline for Segment III (0 to less than 3 employees) until October 2025. However, there is a chronological mismatch: the aid ends in 2025, but the obligation arises in 2027.
This poses a strategic dilemma: Should freelancers apply for the voucher now and acquire software they might not fully use until 2027, or wait and risk losing the subsidy? Experts recommend taking advantage of current funds, ensuring that the digitizing provider contractually commits to maintaining the update to Veri*factu when it comes into force, without additional costs. It is likely that the Government will have to propose new lines of aid (e.g., “Digital Kit 2.0” or extensions of Next Generation funds) to cover the valley period of 2026.
Comparative Perspective: The Basque Model (TicketBAI)
To anticipate the future of Veri*factu in the rest of Spain, it is instructive to observe the experience of the Basque foral treasuries with TicketBAI, an analogous system that is already fully operational.
Although they share the philosophy (invoice chaining, QR, submission to Treasury), there are operational differences:
- Universality of Submission: In TicketBAI, submission to the Foral Treasury is mandatory in real-time (or near real-time) for everyone. In Verifactu (common territory), submission is optional (“Verifactu” mode) versus local storage (“Non-Veri*factu”).
- Validation: TicketBAI validates the invoice before or during issuance.
- Deductions: The Basque treasuries implemented powerful tax deductions (up to 30-60% of the investment) to incentivize early adoption.
The Basque experience demonstrates that, after initial resistance and technical difficulties, the system significantly reduces fraud and simplifies formal obligations (such as VAT drafts). It is foreseeable that the AEAT will study the “pain points” of the TicketBAI implementation to smooth the landing of Veri*factu in 2027.
Strategic Roadmap and Conclusions
The postponement of Veri*factu until 2027 should not be interpreted as a signal for relaxation, but as an opportunity for an orderly and safe transition. The digital transformation of taxation is irreversible; only the cruising speed has been adjusted.
Recommendations for Companies and the Self-Employed
- Systems Audit (2025): Evaluate if current software is “legacy” or if the provider has a clear roadmap towards Veri*factu. If Excel is used, plan to abandon this practice.
- Taking Advantage of Subsidies (2025): Execute the Digital Voucher before October 2025 to finance the acquisition of licenses for compliant software.
- Pilot Tests (2026): Do not wait until January/July 2027. Starting to operate with adapted systems in 2026 allows for detecting integration errors and training administrative staff without the pressure of immediate sanctions.
- Culture of Compliance: Assume that fiscal transparency will be total. Any discrepancy between invoicing and accounting will be automatically detected by AEAT algorithms.
Final Conclusion
The Treasury’s decision to postpone Veri*factu is a measure of political and technical realism. It avoids a scenario of administrative chaos and allows the developer ecosystem to mature its solutions. However, it keeps the final objective unchanged: a data-driven tax administration, where fiscal control is exercised in real-time and unfair competition based on tax fraud becomes technically impossible.
For companies in Spain, the message is clear: the stopwatch has restarted, but the finish line remains the same. Fiscal digitalization is not an option; it is the license requirement to operate in the economy of the next decade. The 2027 extension is, ultimately, stoppage time that must be used with strategic intelligence.
