The extension bought businesses another year. It bought nothing for anyone writing an invoicing system, where the fine runs to €150,000 per product per year.
Most of what you will read about VeriFactu right now says the same reassuring thing: it has been put back to 2027, relax. That is true for the business issuing the invoices. It is not true for whoever wrote the thing issuing them.
What actually happened
The rules come from Real Decreto 1007/2023. They were then pushed back a year by Real Decreto-ley 15/2025, dated 2 December 2025 and in force two days later.
The new dates for taxpayers:
- 1 January 2027 — companies paying Impuesto sobre Sociedades
- 1 July 2027 — everyone else obliged, including autónomos taxed under IRPF
So a shop, a clinic or an estate agency has another year to move to compliant software. Fine.
The part that did not move
The extension covers users of invoicing systems. It does not cover producers and sellers of that software, whose deadline was set at nine months from Orden HAC/1177/2024 — 29 July 2025 — and was left exactly where it was.
The sanction for a non-compliant product is up to €150,000 per year, for each type of system or program marketed. Not per customer. Per product, per year.
If you commissioned a custom platform that issues invoices, that liability sits with whoever built and supplies it. Nobody usually reads that paragraph until an inspection does.
What the rules actually require
Every invoice has to produce a registro de facturación at the moment it is issued, and that record has to carry:
- a hash of its own contents,
- data from the immediately preceding record, so the chain is traceable and a deleted invoice becomes visible as a gap,
- an electronic signature in the cases the regulation names,
- a QR code on the invoice itself,
- and either automatic submission to the AEAT, or storage in a form the AEAT can demand.
The chaining is the interesting engineering constraint. It means invoice records are an append-only ledger, not rows you can edit. Most bespoke billing code we have inherited treats an invoice as an ordinary editable record, and that assumption is what has to go.
If you run a business here
Two questions, and they are quick.
Does your invoicing software have a written VeriFactu declaration? Compliant vendors publish a declaración responsable. If yours cannot point you at one, that is your answer.
Is any of your invoicing custom-built? A plugin someone wrote for your WooCommerce checkout, a script that emails PDFs, an ERP module a freelancer built in 2019. Those are systems under the regulation, and standard platforms do not automatically cover them.
If you build software for clients in Spain
Check what you have already shipped. An invoicing feature written before mid-2025 is almost certainly not compliant, and the liability is not academic.
The honest position with a client is that the platform deadline is 2027, the maker deadline was last year, and closing the gap is cheaper now than during an inspection.
What we would not do
We would not treat 2027 as a reason to wait. The chaining requirement is architectural — it changes how invoices are stored, not how a form looks — and architectural changes are the ones that go badly when they are rushed against a date.