VAT Newsletter May 2025
VAT Newsletter May 2025
Postponement of the obligation to adapt invoicing systems to the VERI*FACTU Regulation under Royal Decree 254/2025
Royal Decree 254/2025 of 1 April amends Royal Decree 1007/2023 with the aim of extending the implementation deadlines of the Regulation governing the requirements that invoicing systems and software used by businesses and professionals must meet (VERI*FACTU), as set out in Article 29.2.j) of the General Tax Law.
One of the key changes introduced by this new Royal Decree is the extension of the deadlines for adapting IT systems: corporate income taxpayers referred to in Article 3.1.a) of Royal Decree 1007/2023 must have their systems adapted no later than 1 January 2026. All other taxpayers — including self-employed individuals, PIT taxpayers engaging in economic activities, non-resident taxpayers with a permanent establishment in Spain, and entities under the income attribution regime — will have until 1 July 2026 to comply.
Additionally, producers and distributors of invoicing systems must offer compliant products within nine months from the entry into force of Order HAC/1177/2024 of 17 October. This sets the deadline for adaptation at 29 July 2025. The same timeline applies to the Spanish Tax Agency (AEAT), which must have the service operational to receive billing records from compliant invoice issuance systems by that date.
An important amendment is also introduced in Article 4 of the Regulation, which more precisely defines the scope of application, excluding, among others, invoices issued from permanent establishments located abroad. Moreover, it clarifies that taxpayers using the Immediate Supply of Information (SII) system for VAT books are also excluded with respect to invoices issued by the recipient or by third parties, as the SII ensures sufficient traceability and control by reporting invoice data directly.
In parallel, Article 6 is amended to reinforce that, even when a third party physically issues the invoice, the taxpayers performing the supply of goods or services remain responsible for fulfilling the obligations set out in the VERI*FACTU Regulation and in the Invoicing Regulation (Royal Decree 1619/2012 of 30 November).
Finally,