Verifactu and the new deadlines: what’s changing, what stays, and what you need to know

Verifactu is the name commonly used for the regulation promoted by the Spanish Tax Agency (AEAT) under the Anti-Fraud Law framework. It regulates Invoicing Software Systems to ensure traceability and prevent manipulation (RRSIF). Until now, the deadlines to use anti-fraud-compliant systems were January 1, 2026 for companies, and July 1, 2026 for the rest of taxpayers, as long as they were not covered by the Immediate Supply of Information (SII).

But before we get into what has changed, we want to start with the obvious: many companies, professionals, and software providers have already invested time, money, and resources to adapt ahead of the deadline. Meetings, development work, integrations, testing, legal advice, internal process changes… and now, suddenly, another twist. It’s completely normal to feel tired and confused about what happens next.

New Verifactu compliance deadlines

After the Council of Ministers meeting on December 2, a change to the taxpayer deadlines was announced. On Wednesday, December 3, the Royal Decree was published in the BOE, confirming the extension of the deadlines for the mandatory use of Verifactu:

• January 1, 2027: taxpayers subject to Corporate Income taxpayers
• July 1, 2027: individuals (freelancers/self-employed)

So what does this update really mean, and what are the implications? The most important thing here is to be crystal clear on what changes and what stays the same.

What changes: more room for late adopters

This timeline adjustment means that, in practice, those who had not yet started their transition to Verifactu now have more time to comply. In other words, this is not a delay of the regulation itself, but an extension of the compliance deadlines for late adopters, giving them 12 additional months to get ready properly.

And that matters, because the risk of misinterpretation is real: taking away only the headline “it’s not mandatory until 2027” can create a false sense of security and, in many cases, turn into a real problem.

What stays the same: software should already be complying since July 2025

Here’s the message that needs to be very clear: the go-live for invoicing software developers and vendors has already been in effect since July 29, 2025. That hasn’t changed, and we can see it directly in the Royal Decree published on December 3:

“Taxpayers referred to in article 3.2 (software manufacturers), in relation to their activities of production and commercialization of the software systems, must offer products fully adapted to the regulation within a maximum period of nine months from the entry into force of the ministerial order referred to in the third final provision of this Royal Decree, without prejudice to the mandatory adaptation of systems included in multi-year maintenance contracts in accordance with the dates indicated above.”

This means that any company that purchases, switches, or updates its invoicing software system must do so using software that is already compliant with the anti-fraud requirements.

As explained in the table on page 5 of the AEAT FAQ document (table on page 5):

“(…) July 29, 2025, which is when producers and distributors of invoicing software systems (SIF) are required to provide only adapted SIF, except in the case of existing maintenance contracts (…). This is a key date for producers and distributors.”

Put simply: even if late adopters are given more time to reach the taxpayer deadlines, the software market cannot pause. The requirement for software to be ready was already being applied, and it will continue to be applied.

The big question: should companies that already started using Verifactu continue doing so?

One of the most confusing points right now is this: what should companies do if they were already using Verifactu before the deadline extension? The answer, at this stage, is not straightforward, because the information published so far is not entirely consistent.

On one hand, the AEAT FAQs state that during the testing period (which now extends until the end of 2026 or June 2027, depending on the taxpayer type), it is possible to stop sending Verifactu records and switch back to another SIF, even a non-adapted one, as long as there is still no formal obligation to comply. This interpretation suggests that those already in the system could “exit” voluntarily during 2026 without major restrictions.

However, the AEAT has also clarified the opposite. If a company has submitted Verifactu records during a financial year, it must continue operating under Verifactu until December 31 of that same year. The company may renounce the system only for the following year, and must report the “FechaFinVeriFactu” before the end of the calendar year. This aligns with Article 17 of the RRSIF, which regulates continuity and renunciation.

Both interpretations stem from the same legal framework but lead to different conclusions, placing many companies in a difficult position: can they stop sending records today, or must they stay in the system until year-end?

The reality is that, as of today, there is no fully consistent official position, and it is reasonable to expect that the AEAT will refine its communication as the rollout progresses.

At fiskaly, we prefer to remain cautious: although we understand that, in an exceptional scenario like this, the Administration may apply some practical flexibility, the responsible recommendation is to follow what is written in the regulation.

In other words:

• If Verifactu records have already been submitted in 2025, the safest option is to remain in the system until December 31 and report the end date if you wish to leave in the following year.

  If no records have been sent yet, there is more room to maneuver, but decisions should be made in alignment with the software provider and within the limits of the system to avoid inconsistencies in transmitted data.

In a context of ongoing changes and not-always-aligned messages, it’s best not to make decisions based on optimistic interpretations, but rather on what is legally clear—while staying attentive to further official clarifications.

Multi-year maintenance contracts: more flexibility, but be careful

The Royal Decree also puts special focus on multi-year maintenance contracts. This is the main scenario where there may be more flexibility, but it should not be mistaken for a general extension.

The idea that “it’s not mandatory until 2027” may sound comfortable, but in practice, it can delay critical decisions (migration, upgrades, vendor selection) and increase risk when the moment to comply truly arrives, with less operational room than it may seem today.

Next steps: a more gradual transition, but Verifactu is not stopping

Overall, the updated calendar allows for a more gradual transition for those who were running late, but Verifactu is still moving forward. This is not about switching anything off. It’s about gaining time to do things properly, and the sooner you use that time, the better:

• Test integrations with more control, without last-minute urgency
• Fine-tune internal processes, training, and support
• Validate data and real-world scenarios before compliance becomes a race against the clock for taxpayers

The key nuance is this: the regulation has not been stopped. An additional window has been opened for late adopters to catch up, but it is not, in any way, an invitation for those who are already compliant to stop.

Now more than ever: choosing the right partner matters

This timeline adjustment may be good news for those who needed some breathing room, but it’s also a reminder: regulatory changes and nuances happen, and they can impact costs, roadmaps, and risk.

That’s why it’s more important than ever to choose a trusted partner that stays by your side throughout the journey. We’re seeing that in-house development, which can look like the most cost-effective option on paper, quickly turns into a real cost: staffing, maintenance, uncertainty, unexpected changes…

That’s where an API like fiskaly SIGN ES makes a difference:

• No need to overstaff internal teams with hires that later become uncertain
• Scalable, and kept up to date with the regulatory framework
• Reduces the risk of your roadmap shifting every time there’s an update
• And, especially relevant now: if the regulatory rollout moves, your costs move too. Until you start using it, you pay €0.

From our experience across other European markets, the software providers with the biggest market share today are often the ones who moved early and became compliant well before the deadline. They didn’t just gain an advantage over competitors; they turned it into market trust, stronger positioning, and growth.

Our approach is simple: no rush, but no pause. Let’s use this period to test the solution, run quality checks, and reach 2027 with a solid, surprise-free integration. At fiskaly, we want you to feel supported at every step. Whatever your question or concern is, write to us and we’ll solve it together.