Key effective dates for Verifactu
Unlike similar systems in other regions, Verifactu extends the obligation beyond tax obligors. Under Verifactu, in addition to taxpayers, there are entities that must comply with the regulation even before the tax obligors themselves: the computerized invoicing software (SIF).
Therefore, when explaining the effective dates of Verifactu, it is necessary to distinguish between computerized invoicing software on one hand, and tax obligors on the other.
Below, we share the key effective dates for Verifactu:
- July 29, 2025: This is the date by which computerized invoicing software (SIF) must be compliant with Verifactu.
- January 1, 2026: Expected mandatory date for legal entities.
- July 1, 2026: Effective date for self-employed individuals.
Confusion regarding deadlines and postponements
There is confusion among invoicing software providers and tax advisors about the actual effective date of Verifactu. It is common to find managers of computerized invoicing software (SIF) claiming that the obligation has been postponed to 2026. Similarly, it is common to find professionals from limited companies who assume they must comply with Verifactu by July 2025. Both groups are mistaken, and this is due to the existing confusion around the Verifactu effective dates.
The so-called Verifactu Regulation, under Royal Decree 1007/2023 of December 5, establishes in its Fourth Final Provision ("Entry into force and effects") the date July 1, 2025 as the effective date of Verifactu for taxpayers. It also states that the mandatory date for computerized invoicing software (SIF) will be nine months after the publication of the Ministerial Order intended to clarify the technical requirements of Verifactu. In December 2023, the date of the Royal Decree, said Ministerial Order was pending drafting and publication in the Official State Gazette (BOE).
The Ministerial Order was finally published on Monday, October 28, 2024 (Order HAC/1177/2024). Adding nine months to the publication date yields the key date of July 29, 2025 as the definitive effective date of Verifactu for computerized invoicing software.
Once this date was established for the SIF, the previous date of July 1, 2025 for taxpayers no longer made sense, as the Tax Agency expects taxpayer compliance to be largely achieved through the adaptation of invoicing software. In other words, the effective date for legal entities and self-employed individuals must be later than the SIF deadline. That is why the deadline for tax obligors has been postponed to 2026.
Possible future date changes and adoption pace
When predicting the definitive effective dates and anticipating possible future extensions, it is worth noting the experience in the regional tax authorities with the TicketBAI system. In this system, similar in many ways to Verifactu, there were notable delays in the implementation schedule from the initially planned dates to the deadlines that were finally imposed.
Another relevant factor for predicting Verifactu adoption is the essential role that tax incentives played in the regional tax authorities to reward early adoption. Many taxpayers, seeking to take advantage of various tax benefits, complied with the new regulation before the mandatory deadline. It is foreseeable that something similar will happen with the adoption of Verifactu.
Implications of the Verifactu effective date for computerized invoicing software
If you are an invoicing software, an ERP, or any type of software that provides functionality for your users to issue invoices, you should know that by July 29, 2025, your users must have the ability to include the well-known Verifactu QR code on the invoices they issue.
This does not necessarily mean you must place the QR code on all invoices for all users. However, you must be prepared to offer this functionality to whoever requests it.
The penalties for non-compliance for computerized invoicing software are very substantial. Therefore, you must plan ahead and find a way to comply with Verifactu before the mandatory date of July 29, 2025. To do so, you have two options:
- Integrate directly with the Tax Agency Administration API, a complex development that will require many hours of work and ongoing maintenance.
- Choose to use an API like Verifacti's, designed for computerized invoicing software and ERPs seeking a simple, fast, and cost-effective compliance solution.
Effects of the Verifactu effective date for legal entities and self-employed individuals
If you are a taxpayer, the key deadline for you will be 2026. That year, you must ensure that the invoices you issue comply with the Verifactu system.
In many cases, compliance will happen naturally and without any effort on the part of the taxpayer. This will be the case when the tax obligor uses a computerized invoicing software that, by legal obligation, will guarantee compliance for that user.
In other cases, however, the taxpayer will need to make an effort to comply with the mandatory deadlines during 2026. A good example would be companies with custom proprietary software. Companies in this situation must ensure that their software integrates correctly with Verifactu, carrying out the necessary developments and changes.
For those taxpayers who require a development effort before the mandatory deadline in 2026, there are two options:
- Direct integration with the Administration API.
- Integration with an API like Verifacti's.
Development timelines to be ready in time for the Verifactu effective date
Developers facing the challenge of integrating their software with Verifactu before the mandatory date in 2025 or 2026 should consider the following timelines:
- In the case of a direct integration with the Tax Administration API, it is common to require between three and six months of development. This period will vary depending on the complexity of the software to be adapted, the programming language used, and the developers' level of knowledge in development and invoicing.
- In the case of choosing an API like Verifacti's, the estimated integration time is significantly reduced to just a few days.