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VeriFactu Autónomos Deadline: Not 2026 — the Real Dates

By CHANGE-ME Your Name · Updated 2026-10-10

The short answer: there is no 1 July 2026 obligation

If someone told you VeriFactu becomes compulsory for companies on 1 January 2026 and for autónomos on 1 July 2026, that calendar is dead. Those dates came from Real Decreto 254/2025, de 1 de abril (BOE of 2 April 2025), and they were repealed before they ever took effect.

Real Decreto-ley 15/2025, de 2 de diciembre (BOE of 3 December 2025, in force 4 December 2025) rewrote disposición final cuarta of RD 1007/2023 through its own disposición final primera and pushed everything a year out. Congress convalidated it on 11 December 2025. Worth knowing why almost nobody saw it coming: the decree-law is mainly about investment by local and regional authorities — VeriFactu was a rider in a final provision.

So the user deadline has moved twice: 1 July 2025 in the original RD 1007/2023, then 1 January / 1 July 2026 under RD 254/2025, now 2027. A third move is announced but not enacted (below). If a page tells you July 2026, it was written before December 2025 and never updated.

Here is where we actually stand today, 10 October 2026.

The deadlines currently in force

Source: consolidated text of RD 1007/2023 in the BOE (consolidation last updated 3 December 2025).

Note the asymmetry: your software vendor's deadline passed over a year ago, even though yours has not. RDL 15/2025 moved the user dates; as far as the consolidated texts show, it did not touch the producer clock. If your provider is still saying "we're working on it", that is a provider problem, not a regulatory grace period.

Why 1 January for companies and 1 July for autónomos? The norm gives no reason — it is simply a staggered rollout. Don't read anything into it beyond the dates themselves.

The October 2028 announcement: a plan, not the law

On 5 October 2026 the Ministerio de Hacienda published an informative note announcing a previsión de ampliación del plazo — an intention to move the adaptation deadline to October 2028. The AEAT links it from its VeriFactu landing page (page last updated 8 October 2026).

Three things to be precise about:

1. It is not in the BOE. Until a royal decree amending RD 1007/2023 is published, 1 January 2027 / 1 July 2027 remain the legally binding dates. The AEAT's own nota informativa on deadlines, updated 7 October 2026 — two days after the Hacienda note — still states them.
2. The exact day in October 2028 is unknown. Nobody can tell you "the new deadline is 1 October 2028", because no normative text says so.
3. Whether companies and autónomos converge on a single 2028 date is reported but unconfirmed. Several advisory firms say yes; I could not verify it from the Ministry note's own text, so treat it as expectation, not fact. It is also unresolved whether the move would cover only obligations "not yet applicable", leaving anything on the 2027 track.

The stated rationale is useful, though: Hacienda wants to align VeriFactu with mandatory B2B e-invoicing for businesses up to €8M of turnover, so an SME or autónomo does not have to re-tool invoicing twice in twelve months.

And the most important line in the note, if you are wondering whether to bother now: the technical guarantees — integrity, traceability, inalterability — will be maintained "en términos sustancialmente equivalentes". Adapting your invoicing now is not wasted work.

One housekeeping point: the AEAT's VeriFactu FAQs are marked actualizadas a 21 de julio de 2026, so they predate the announcement entirely. They are still the best source on the mechanics, but they say nothing about 2028.

VeriFactu is not the obligatory electronic invoice

This is the biggest source of confusion in the topic, and it produces headlines like "VeriFactu moves to October 2027" — wrong, because that date belongs to a different obligation.

• VeriFactu (RD 1007/2023) = requirements on your invoicing software: unalterable records, hash chaining, QR code, optional automatic transmission to the AEAT.
• B2B electronic invoicing (Ley 18/2022 "Crea y Crece" → RD 238/2026, de 25 de marzo → Orden HAC/1028/2026, de 2 de octubre, BOE of 5 October 2026, in force 6 October 2026) = an obligation to issue, send and receive invoices in a structured electronic format between businesses, plus report invoice status and payments. Entry into force of that order is what started the clock.

The e-invoicing calendar, counted from 6 October 2026, per the AEAT:

The public e-invoicing solution will be run by the AEAT and must be available at least two months before the first effective application date.

Are you even in scope?

Obliged under article 3.1 of RD 1007/2023, if you use invoicing software for all or part of your activity: IS taxpayers, IRPF taxpayers with economic activities (autónomos), IRNR taxpayers with a permanent establishment, and income-attribution entities carrying on economic activities. Being in módulos or recargo de equivalencia changes nothing — you are still an IRPF taxpayer with an economic activity.

Outside scope or excluded:

• SII filers. Article 3.3 excludes taxpayers keeping their VAT registers under article 62.6 RIVA. If you are on the Suministro Inmediato de Información (VAT groups, REDEME, large turnover), VeriFactu does not apply. Clean exit, and almost no article mentions it.
• Foral territories. Article 1.3: the regulation applies without prejudice to the regímenes forales. For País Vasco and Navarra it bites on taxpayers with tax domicile in common territory. Domiciled in the Basque Country or Navarre, you are in TicketBAI / Batuz territory — a different system with its own calendar. Canarias, Ceuta and Melilla have their own specific rules.
• Entities fully exempt under article 9.1 Ley IS. Partially exempt entities (art. 9.2–9.4) are covered only for operations generating taxable, non-exempt income.
• Operations you are not required to invoice at all. Also excluded under article 4: certain self-billing and third-party billing cases, operations invoiced through foreign permanent establishments, and operations under disposiciones adicionales 3ª and 6ª of RD 1619/2012. Note what that exclusion is not: invoicing a client abroad from Spain is in scope — it's the foreign permanent establishment that takes the operation out.
• Existing AEAT-authorised special invoicing systems stay valid.
• Article 5 escape hatch: the head of the AEAT's Departamento de Inspección Financiera y Tributaria can, on request, disapply the regulation for specific sectors or taxpayers, or where technical circumstances make compliance impossible. Temporary and conditional disapplication is allowed.

There is no low-volume threshold anywhere in the norm. Five invoices a year still puts you in scope if you use software to issue them.

Is your current method already illegal? The honest checklist

Short version: nothing you are doing today is illegal today. Your obligation starts on 1 July 2027 (or whatever date replaces it). The question is whether your method will work then.

On Word and Excel, ignore the internet's two extremes. RD 1007/2023 binds users of sistemas informáticos de facturación. There is no AEAT page that flatly bans spreadsheets; the AEAT does confirm paper invoices remain legal and does offer an app precisely for people with no system. But a spreadsheet acting as your invoicing system cannot produce a chained, unalterable record with a QR code, so once your date arrives it will not meet Orden HAC/1177/2024 and the Resolución of 18 December 2024. Secondary sources (Infoautónomos among them) argue that purely manual, occasional invoicers can keep their own records if they meet legibility, conservation and inalterability conditions. That is an interpretation, not an AEAT ruling. Don't build a plan on it.

On foreign software: there is no nationality requirement in the norm. The test is whether the system meets the RRSIF and ministerial-order requirements and whether the producer issues a declaración responsable stating so. The practical problem is that many non-Spanish tools have not implemented the Spanish hash chain, QR and record-transmission spec. Ask for the declaración responsable in writing — if they can't name the document, they're not ready.

VERI*FACTU mode vs the other one

A compliant SIF can work in two modes:

• VERI*FACTU mode: every invoicing record is transmitted automatically to the AEAT. Lighter duties — no electronic signature on records, no event-log requirement. The QR lets the AEAT validate the invoice content.
• No-VERI*FACTU mode: records stay in your system, but the system must apply an electronic signature to each record and keep a registro de eventos. The QR still carries invoice data.

For a one-person autónomo, VERI*FACTU mode is normally the simpler choice. The QR is mandatory on all invoices, including simplified ones (tickets); on structured electronic invoices it can be replaced by the content it encodes. The phrase "Factura verificable en la sede electrónica de la AEAT" or "VERI*FACTU" is required only when your system sends all records to the AEAT under articles 15–16.

The AEAT's application

The AEAT offers an invoicing application in its Sede Electrónica — its own guide calls it gratuita — aimed at small businesses with no system of their own. It produces a printable invoice with a QR code and stores the VERI*FACTU record.

Two limitations most articles omit:

• it issues only complete invoices, not simplified invoices (tickets) — a dealbreaker for retail and hospitality;
• it cannot handle invoices with multiple recipients.

For a consultant or freelancer issuing a handful of invoices a month, it is genuinely enough — and it costs nothing, which matters when you're adding up fixed monthly costs like the autónomo monthly fee for 2026.

Two traps nobody warns you about

1. Possession is an offence. Under article 201 bis LGT, these are all infracciones graves:

That third row is the one that catches autónomos. After your deadline, merely keeping a legacy program still capable of issuing invoices may be sanctioned. The AEAT's position: you may keep old software only if it can no longer issue invoices (uninstalled, or invoice creation disabled), and it recommends exporting your historical records rather than keeping the program around.

2. The mode lock. We are currently in what the AEAT explicitly calls a periodo de pruebas. Until 31/12/2026 or 30/06/2027 (depending on your taxpayer type) you can start issuing VERIFACTU invoices and then go back to another system, including a non-adapted one, with no commitment. After your obligation date, if you start sending VERIFACTU records you must stay in that mode at least until the end of that calendar year, counted from your first effective send. So experiment freely now; switching casually later, no.

One claim doing the rounds — that the AEAT allows "six months of tolerance for errors" — I could not locate on any AEAT page. The testing period is real; an error amnesty is not something I'd rely on.

What I'd actually do before July 2027

1. Check whether you're out of scope at all: SII filer, or tax domicile in País Vasco/Navarra (then it's TicketBAI/Batuz).
2. Email your provider one question: do you issue a declaración responsable of compliance with RD 1007/2023 and Orden HAC/1177/2024, and when? Keep the reply.
3. If the answer is vague, or you invoice from Word/Excel, test the AEAT app this quarter — during the testing period you can walk away with no consequences.
4. Decide your mode (VERI*FACTU vs signed records + event log) before your date, not after, because of the year-end lock.
5. Plan the exit from your old program: export history, then uninstall or disable invoice issuance before your deadline.
6. Don't buy anything twice. The "substantially equivalent" wording means a tool compliant today should survive the 2028 reshuffle, and the same tool will likely need to handle B2B e-invoicing later.

Starting out rather than already trading? Build compliant invoicing in from day one — it belongs alongside the other steps in how to register as an autónomo in Spain in 2026, and if you're going for the reduced quota, check the tarifa plana requirements for 2026.

Still uncertain — watch these

• The October 2028 date has no BOE text and no fixed day. Until it does, plan around 1 July 2027.
• Whether 2028 applies as one single date for companies and autónomos is reported, not confirmed.
• Whether the 2028 move covers only obligations "not yet applicable" is unresolved.
• A contentious-administrative appeal (recurso 1586/2026) exists against RDL 15/2025, but it targets a different final provision (Catalan civil servants), not the VeriFactu dates.

Check the AEAT VeriFactu hub and the BOE consolidated text of RD 1007/2023 before acting on anything you read about this — including this article. The user deadline has already moved twice.

FAQ

Official sources

• Real Decreto 1007/2023 — consolidated text (BOE)
• Real Decreto-ley 15/2025, de 2 de diciembre (BOE)
• Real Decreto 254/2025, de 1 de abril (BOE)
• Orden HAC/1177/2024, de 17 de octubre (BOE)
• Resolución de 18 de diciembre de 2024 (BOE)
• Orden HAC/1028/2026, de 2 de octubre — solución pública de facturación electrónica (BOE)
• Ley 58/2003 General Tributaria, art. 201 bis (BOE)
• AEAT — Sistemas informáticos de facturación y VERI*FACTU
• AEAT — Nota informativa sobre la ampliación del plazo de adaptación
• AEAT — VERI*FACTU: cuestiones generales
• AEAT — VERI*FACTU: preguntas frecuentes
• Ministerio de Hacienda — nota informativa VeriFactu, 5 de octubre de 2026 (PDF)
• AEAT — Solución pública de facturación electrónica (7 October 2026)
• AEAT — Guía de la aplicación gratuita VERI*FACTU