It’s very common to mix up two obligations that aren’t the same thing: Verifactu and mandatory electronic invoicing. They overlap in time and both talk about “digital invoicing,” but they regulate different things.
This is not Verifactu
Verifactu requires the software you invoice with to record every invoice in a way that can’t be altered without leaving a trace. It’s an obligation on the software you use, not on the format you send the invoice to your client in. We explain it with specific dates in Verifactu: what it is and when it affects you.
What mandatory electronic invoicing is (Ley Crea y Crece)
This is a different rule: the Ley 18/2022 on business creation and growth requires companies and self-employed workers to issue and receive invoices between each other in a structured electronic format, not just any PDF, but a file a computer system can read and interpret without manual intervention, and to be able to report the status of that invoice (paid, pending, rejected).
Who it applies to
Every company and self-employed worker that invoices another company or self-employed worker (B2B transactions). It doesn’t affect invoices you issue to individuals, and it has nothing to do with whether you use invoicing software or not — that’s what Verifactu regulates, not this rule.
When it becomes mandatory
The regulation that develops this obligation, Royal Decree 238/2026, of 25 March, has already been approved and published. It sets a 12-month timeline for companies with annual turnover above €8 million, and 24 months for the rest of companies and self-employed workers. That countdown is now running: Order HAC/1028/2026, published on 5 October 2026, came into force on 6 October. The obligation therefore starts on 6 October 2027 for companies with turnover above €8 million and on 6 October 2028 for all other companies and self-employed workers. These dates do not change with the possible Verifactu postponement: it is a different rule (see Verifactu postponed to October 2028).
What you can do already
The most useful thing right now is to check whether your invoicing software can generate structured electronic format (Facturae or other equivalent standards). In practice, this is usually the same technical requirement Verifactu asks for, so checking one leaves you on track for the other.