Revised on 7 November 2026. Should any information have changed, please notify me and I shall update it.
An artist who invoices a gallery, a company or a town council faces two different reforms that are often confused. One regulates the software used to issue invoices: this is Verifactu. The other mandates that invoices between professionals must be electronic: this is the electronic invoice under the 'Crea y Crece' Law. They have different rules, dates and reasons, although since October 2026 the Government has sought to align them. Both are explained here with the state of the regulations as of 7 November 2026.
Verifactu in a nutshell
Royal Decree 1007/2023 sets the requirements that computer systems used by businesses and professionals to issue invoices must meet. Each invoice generated by software leaves a chained and unalterable record, with a QR code that allows it to be verified. The software can operate in two ways: by sending each record to the Tax Agency in real time, which is the VERI*FACTU mode, or by storing them with additional guarantees without sending them.
The regulation applies to those who issue invoices using a computer system. Those who issue invoices solely by hand remain outside these technical requirements, although they retain all other invoicing obligations. The Tax Agency addresses the case of those who use a spreadsheet template or word processor in its frequently asked questions: if this applies to you, consult them before making a decision.
The Verifactu timeline
The dates have changed twice, and a third change has been announced but not yet published.
The original 2023 text mandated compliance from 1 July 2025. Royal Decree 254/2025 moved it to January 2026 for corporations and July 2026 for others. Royal Decree-Law 15/2025, published on 3 December 2025 and ratified by Congress on 11 December, set 1 January 2027 for Corporate Income Tax taxpayers and 1 July 2027 for other obligated parties, including self-employed individuals.
On 5 October 2026, the Ministry of Finance announced in an information note that it would postpone the pending obligations until October 2028, so that they coincide with electronic invoicing. An announcement is not a regulation. As of the revision date of this guide, the postponement had not been published in the Official State Gazette (BOE).
For a self-employed artist, the mandatory date while nothing else is published is 1 July 2027. The Treasury has announced October 2028, but that announcement does not yet supersede the current date. Plan your adaptation without treating the postponement as an acquired right, and check the BOE before paying for software in haste.
Electronic invoicing between professionals
Law 18/2022, on the creation and growth of companies, mandates the issuance and receipt of electronic invoices in operations between businesses and professionals. Its development arrived in two steps: Royal Decree 238/2026, of 25 March, and Order HAC/1028/2026, of 2 October, which regulates the Tax Agency's public electronic invoicing solution and came into force on 6 October 2026. From that day, the deadlines begin: twelve months for those who invoiced more than 8 million euros the previous year and twenty-four months for the rest. For almost any artist, the obligation begins on 6 October 2028.
This affects your invoices to galleries, publishers, companies, foundations and other professionals. It does not affect your sales to private individuals. Invoices to public administrations follow their own regime, that of Law 25/2013 and FACe, which is explained in the guide on getting paid by an administration.
Anyone receiving an electronic invoice must also communicate their acceptance or rejection and the date of actual payment. For those who are paid late by their clients, this recorded data is not a minor detail. The Tax Agency will offer a public electronic invoicing solution, which must be available at least two months before the first application date.
What to do now
If you issue few invoices by hand, you do not have to change anything today. Follow the BOE closely and decide in 2027.
If you use invoicing software, ask your provider if they have the responsible declaration required by the regulation and if they intend to integrate electronic invoicing. Be wary of offers that urge you to sign up "before the deadline": it has moved twice and a third change has been announced.
If you invoice galleries or companies, be aware that towards 2028 they will ask you for invoices in a structured format and that your clients will inform the Treasury when they pay you.
And do not forget that the General Tax Law has sanctioned the possession of invoicing software that does not meet the requirements since 2021.
Further reading
- How to invoice the sale of artwork in Spain: VAT and withholding tax
- Registering as an artist with the tax authorities: group 861 and form 036
- Getting paid by an administration: minor contracts, FACe and payment deadlines
On the open conversation
If you advise self-employed individuals or develop invoicing software and notice an error in the timeline, please write to me: this guide will be updated whenever the regulation changes. This notebook remains open.
Sources
- Royal Decree 1007/2023, of 5 December, regulation on the requirements for computerised invoicing systems.
- Royal Decree 254/2025, of 1 April.
- Royal Decree-Law 15/2025, of 2 December, and ratification agreement.
- Royal Decree 238/2026, of 25 March, which develops the mandatory electronic invoicing system between businesses and professionals.
- Order HAC/1028/2026, of 2 October, which regulates the public electronic invoicing solution.
- Information note from the Ministry of Finance of 5 October 2026 regarding the postponement of Verifactu, according to information from the EFE agency.
- Law 58/2003, General Tax Law, art. 201 bis.