Electronic Invoicing and Verifactu
Mandatory electronic invoicing between businesses and professionals has just taken a decisive step forward. The publication of Order HAC/1028/2026, dated October 2, completes the technical development of the public electronic invoicing solution and, most importantly for companies and the self-employed, activates the implementation schedule for this new requirement. The Order comes into effect on October 6, 2026. From that date, the deadlines for the progressive incorporation into the new system begin to count. When will electronic invoicing become mandatory? Not all business owners and professionals will need to adapt at the same time. In general, the schedule is as follows:
October 6, 2027. It will be mandatory for business owners and professionals whose annual turnover exceeded 8 million euros during the previous calendar year.
October 6, 2028. The requirement will apply to all other business owners and professionals within the scope of the regulation.
October 6, 2029. For certain individuals and entities under the income attribution regime with a turnover equal to or less than eight million euros, the additional period provided for certain obligations related to communicating invoice statuses will end.
Please note: The eight-million-euro threshold must be calculated according to the definition of turnover under VAT regulations. It does not necessarily coincide exactly with the company's accounting revenue.
What will actually change? The new electronic invoice is not simply about replacing paper with a PDF sent via email. Invoices must use structured electronic formats capable of being processed automatically by various systems. The public solution will use the European EN 16931 electronic invoice model and the UBL syntax established by the Order. A PDF, on its own, does not constitute the structured format required by the new model. Furthermore, the system will allow for tracking certain events after an invoice is issued, such as its rejection or full payment. In certain cases, information related to the due date must also be communicated. Therefore, the invoice will no longer be just a document that is issued and recorded; it will have a much more traceable electronic lifecycle. Will it be mandatory to use the tax authority's platform? Not necessarily. The regulations will allow the use of the AEAT's public electronic invoicing solution or the continued use of private platforms. However, these platforms must be interoperable with the system, and when an invoice is issued via a private solution, a faithful electronic copy must be sent to the public platform in accordance with the terms established by the regulations. This means that companies can continue using their usual software as long as it is prepared to function within the new system. What should you review now? There is still time, especially for SMEs and the self-employed who, in general, must adapt by October 2028. But the clock is already ticking. Those planning to purchase new invoicing software, upgrade their ERP, or change providers should explicitly ask if the solution is prepared to work with structured electronic invoicing, interoperability, status communication, and connection to the public solution. Please note: It is not advisable to choose a program now based solely on current needs. The investment should also account for the adaptation to the electronic invoicing requirements that will arrive over the next two years.
Electronic invoicing and VeriFactu are not the same thing. It is worth repeating this because the overlapping dates can increase confusion. VeriFactu and B2B electronic invoicing are different obligations. VeriFactu focuses primarily on the requirements that computer systems used for invoicing must meet. B2B electronic invoicing, on the other hand, regulates how invoices between business owners and professionals must be issued, exchanged, and managed electronically. The Administration is working to coordinate both systems, but that does not mean they have become a single obligation. An adaptation process that should be planned begins now. The publication of this Order turns an obligation that seemed distant into a project with specific dates. There is no need for hasty decisions, but it is a good time to check which software you are using, what adaptation capacity your provider offers, and how you currently manage the issuance, receipt, correction, and payment of invoices. You will need to change technology, but also some ways of working. Our firm will keep you informed of updates and will review with each client when they need to join the new system and what actions will be necessary before their application date arrives.
Please feel free to contact this professional firm for any questions or clarifications you may have regarding this matter.
