Tax Alert: Royal Decree-Law 15/2025, of 2 December

The purpose of this alert is to inform you that today, December 3, 2025, the Official State Gazette has published the Royal Decree-Law 15/2025 of 2 December, adopting urgent measures to promote investment activity by local authorities and autonomous communities, and amending Royal Decree 1007/2023, of 5 December, approving the Regulation establishing the requirements to be adopted by computer or electronic systems and programmes supporting the entrepreneurs and professionals’ invoicing processes, and the standardisation of invoicing record formats.

Among other measures, this Royal Decree-Law amends Royal Decree 1007/2023 of 5 December, establishing a series of requirements to be met by computerised invoicing systems for certain economic operators (small and medium-sized enterprises, self-employed persons and, in general, all operators not subject to Immediate Information Sharing), better known as the "Verifactu Regulation".

As we have been informing you in previous alerts, the purpose of the Verifactu Regulation is to regulate requirements and technical specifications that must be met by any computer or electronic system or programme, hereinafter generically referred to as a computer system, used by those who carry out economic activities supporting invoicing processes of operations corresponding to their activity, to ensure the integrity, preservation, accessibility, legibility, traceability and inalterability of invoicing records without interpolations, omissions or alterations that are not duly recorded in the systems themselves, with information on all deliveries of goods and services, in accordance with the provisions of Article 29.2(j) of Law 58/2003 of 17 December, the General Tax Law.

The amendment introduced by this Royal Decree-Law consists of a further postponement, until 2027, of the start of application of these requirements.

Indeed, and following the first postponement established by the amendment made by Royal Decree 254/2025 of 1 April, the entry into force of the Verifactu Regulation was scheduled for January 1, 2026, in the case of taxpayers liable for Corporate Tax, while, for other companies and self-employed persons using computerised invoicing systems, the entry into force was set for July 1, 2026.

However, with the approval of Royal Decree-Law 15/2025 of 2 December, there is a further extension of the deadline for compliance with these requirements, insofar as, according to its Explanatory Memorandum, circumstances remain that justify it, motivated both by the necessary adaptation of computerised invoicing systems and by the desirability of ensuring orderly and uniform implementation across the business sector as a whole. 

Consequently, and following this second extension of the deadline, taxpayers liable for Corporate Tax must have adapted their computer systems to the characteristics and requirements established in the Verifactu Regulations by January 1, 2027, while other taxpayers must have the aforementioned computer systems operational before July 1, 2027.

In any case, we remind you that this extension of the deadline is subject to the ratification of Royal Decree-Law 15/2025, of December 2, by the Congress of Deputies, within the thirty-day period established in Article 86.2 of the Spanish Constitution. If it is not ratified within that period, it would cease to have effect.