Verifactu postponed to October 2028: what changes for schools, nurseries and academies

On 5 October 2026, Spain's Finance Ministry said it intends to postpone the outstanding Verifactu obligations until October 2028. The stated reason is to line up the Verifactu timeline with mandatory e-invoicing between businesses, whose implementing order appeared in the BOE, Spain's official gazette, that same day.

Many headlines treated it as settled, and it is understandable that school offices read it that way. There is an important nuance, though: what has been published is an announcement, and the dates still in force are the 2027 ones. This article explains what is known, what is missing and what a school, nursery or academy should do.

What the Ministry announced

The message went out through the Forum of Tax Associations and Professionals, and the Tax Agency (AEAT) circulated it the following day. Its main points:

• New planned date: October 2028, with no specific day, for everyone who did not yet have to comply.
• Reason: to align Verifactu with mandatory e-invoicing and with the future digital reporting requirements of the EU's ViDA directive.
• Technical requirements: the integrity, retention, traceability and immutability requirements for invoice records will stay "substantially equivalent".
• Second phase: the Ministry plans to amend the rule later to adjust its scope and some technical aspects to ViDA.

What the law says today

Until the BOE publishes a provision that changes the timeline, the applicable dates are those in Royal Decree-law 15/2025:

• 1 January 2027: corporate income tax payers.
• 1 July 2027: everyone else who must issue invoices, including the self-employed.

For October 2028 to become the legal date, a new rule is needed. It could be a royal decree amending Royal Decree 1007/2023, with its public consultation, reports and, where applicable, an opinion from the Council of State, or a new royal decree-law.

How we got here

Verifactu's timeline has kept changing for years, which is worth bearing in mind before accepting any new date:

• July 2021: Law 11/2021 on preventing and fighting tax fraud requires invoicing software to guarantee the integrity and immutability of records.
• December 2023: Royal Decree 1007/2023 approves the regulation that develops that obligation, with a first application date in July 2025.
• October 2024: Order HAC/1177/2024 sets the technical specifications that software must meet.
• April 2025: Royal Decree 254/2025 postpones the obligation to January and July 2026, and keeps 29 July 2025 as the date by which software makers must have their systems adapted.
• December 2025: Royal Decree-law 15/2025 postpones it again, to January and July 2027.
• 5 October 2026: the Finance Ministry announces its intention to move it to October 2028.

What Verifactu requires in practice

The postponement changes when, not what. Adapted invoicing software must:

• Generate a record for every invoice issued and another each time one is cancelled.
• Chain the records with a digital fingerprint, so that each depends on the previous one and an invoice cannot be deleted or changed without leaving a trace.
• Include a QR code on the invoice, which lets the recipient check it on the Tax Agency's website.
• Work in one of two modes: VERI\*FACTU, in which the system sends the records to the Tax Agency automatically and the invoice says so with a legend, or the non-sending mode, in which records are signed electronically, an event log is kept and everything is handed to the tax authority on request.
• Have its maker's responsible declaration, certifying that the system complies with the regulation.

It also covers simplified invoices, the old till receipts, which many schools issue at the shop, at the office or for after-school activities.

The election factor

On the same 5 October, the Council of Ministers approved the dissolution of Parliament and called a general election for 29 November. Until that date the Government keeps all its powers; afterwards it becomes a caretaker government, limited in principle to ordinary business except in urgent cases.

Nothing prevents the postponement from being approved in time, but the window is short. If the rule does not arrive before 1 January 2027, companies would have to comply on that date. That is why several firms advise against planning with October 2028 as a certain date for now.

What it means for each type of school

The date that applies to you depends on the owner's legal form, not on the type of teaching:

• Schools, nurseries or academies run as a company: they pay corporate income tax, so today their date is 1 January 2027.
• Foundations, associations and cooperatives: in general they also pay corporate income tax, even under a special regime. Confirm your specific case with your adviser.
• Academies or nurseries run by a self-employed owner: their date is 1 July 2027.

Two clarifications that cause a lot of confusion in education:

• VAT-exempt teaching: the exemption does not take you out of the system. If you issue invoices with a software programme, that programme must comply with the regulation even when the transaction is exempt. We explain it in VAT in academies.
• Invoices to families: Verifactu applies to every invoice the school issues with its software, including those to families, and not only to those sent to companies.

Five common situations

• A private school owned by a limited company, with VAT-exempt teaching, meals and after-school activities. It pays corporate income tax, so today its date is 1 January 2027. Everything it invoices with its software falls under Verifactu: fees, meals, after-school activities and uniform sales.
• A foundation that owns a state-funded private school and charges for meals, transport and after-school activities. Even under the tax regime for non-profit entities, it generally remains a corporate income tax payer. Unless your adviser says otherwise, its date is also January 2027.
• A nursery run as a cooperative. Cooperatives pay corporate income tax under their own special regime, so the same rule applies.
• An academy run by a self-employed owner who invoices with a spreadsheet template. Its date is July 2027. Besides the date, it needs to check whether its way of invoicing falls under the regulation: the Tax Agency's FAQs deal expressly with spreadsheets and word processors.
• An education group with several companies. Each entity has its own date, its own tax ID and its own invoice series. If they share a platform, the software must keep each entity's records separately.

If the school pays tax in the Basque Country or Navarre

Verifactu is a rule of the state Tax Agency. Schools that pay tax to the Basque Country's regional tax authorities have their own system, TicketBAI, with its own timeline, and Navarre regulates its own. If your school is in those territories, the postponement announced by the Ministry does not change your dates: confirm them with your adviser and your regional tax authority.

What to do now

1. Plan with the 2027 dates until the BOE says otherwise. If you are a company, you have less than three months.
2. If you are already adapted, do not go back. An adapted system will remain valid under the new timeline, and using a non-adapted one once it is mandatory can lead to a fine of 50,000 euros per tax year under article 201 bis of the General Tax Law.
3. Ask your provider for its responsible declaration. Software makers must issue one to show that their system complies with the regulation.
4. Confirm with your adviser which date applies to the owner's legal form, especially if the school is a foundation, a cooperative or part of a group.
5. Use the time to tidy up your invoicing: series, items, corrective invoices and receipts that are currently produced outside the programme. We go into detail in the Verifactu guide for schools.

Common mistakes

• Treating the postponement as settled and stopping the project. If the rule does not arrive before January, a company would find itself without an adapted system and with the school year under way.
• Thinking that VAT exemption takes you out of Verifactu. The exemption concerns the tax, not how the software that issues the invoice must work.
• Leaving part of the invoicing outside the software. Meals charged from a spreadsheet or a shop with receipts from another till are separate invoicing systems, and each would have to comply.
• Correcting invoices by deleting them. With an adapted system, an issued invoice is not deleted: it is cancelled, with its record, or corrected with a corrective invoice.
• Asking for the responsible declaration in December. If your provider does not have one, you need to know with time to switch.

And e-invoicing, is it postponed too?

It is a separate obligation with its own timeline. Order HAC/1028/2026, published in the BOE on 5 October, regulates the Tax Agency's public e-invoicing solution and starts the clock on e-invoicing between businesses and professionals: 6 October 2027 for those with turnover above 8 million euros and 6 October 2028 for everyone else.

That shared October 2028 is exactly what the Ministry wants to use for Verifactu. We explain it in detail in the mandatory e-invoicing timeline.

Conclusion

The Ministry's announcement is a clear signal of where the timeline is heading, but it does not change any date yet. A school that pays corporate income tax should keep working towards 1 January 2027, and one run by a self-employed owner, towards 1 July. If the postponement is published, the extra time will be for tidying up invoicing calmly, not for starting from scratch.

Edena generates the record of every invoice in line with Verifactu and has published its responsible declaration. If you want to see it, read how Verifactu works in Edena or book a demo.