Veri*Factu: Extension of deadlines for the adaptation of invoicing IT systems.

As a result of the publication on December 3, in the BOE, regarding the extension of deadlines for the adaptation of invoicing IT systems, we believe it is important to inform about its significance.

In the annex to this notice, you will find the extract of what was published in the BOE regarding this matter. Kriter Software has had available, since before July 29, 2025, the version adapted to all the legal requirements.

This extension of the deadline allows companies and freelancers a little more time to adapt with peace of mind.

However, what does not change is the obligation for software development and/or marketing companies that any software update made from July 29, 2025, onwards must comply with this obligation, as well as any new installation or registration of a new company.

Therefore, all clients who have already adapted do not need to do anything, as they already comply with the requirements.

ANNEX

EXTRACT FROM THE OFFICIAL STATE BULLETIN No. 290 Wednesday, December 3, 2025:

This extract refers uniquely and literally to the requirements that IT systems and programs must adopt.

I. GENERAL PROVISIONS - HEAD OF STATE
24446 Royal Decree-Law 15/2025, of December 2, by which ………, and by which Royal Decree 1007/2023 of December 5 is amended, approving the Regulation that establishes the requirements that IT or electronic systems and programs supporting the invoicing processes of businesses and professionals must adopt, as well as the standardization of invoicing record formats

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Article 3 of this Royal Decree-Law amends the fourth final provision of Royal Decree 1007/2023, extending the adaptation deadlines of invoicing IT systems to the requirements set out in the regulation: for those obliged under Article 3.1.a): January 1, 2027, and for the rest of the obliged under Article 3.1: July 1, 2027. Likewise, the deadline for IT system producers and marketers is adjusted, maintaining the nine-month rule from the entry into force of Ministerial Order HAC/1177/2024, without prejudice to mandatory adaptation before the new deadlines indicated. The Royal Decree-Law is completed with a single additional provision and three final provisions.

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Regarding the modification of the adaptation deadlines of invoicing IT systems to the requirements set out in Royal Decree 1007/2023, of December 5, urgency is justified by the impossibility of processing the necessary regulatory amendment before the enforceability of these requirements which, if not processed, and according to its fourth final provision, will be enforceable on January 1, 2026.

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First final provision.
Amendment of Royal Decree 1007/2023, of December 5.
The fourth final provision is drafted as follows:
"Fourth final provision. Entry into force and effects.
This Royal Decree and the Regulation shall enter into force the day after their publication in the “Official State Bulletin”. Nevertheless, taxpayers referred to in Article 3.1.a) must have adapted their IT systems to the characteristics and requirements established in this Regulation and its development legislation before January 1, 2027. The rest of the taxpayers mentioned in Article 3.1 must have the said IT systems operational before July 1, 2027. Taxpayers of Article 3.2, in relation to their activities of production and marketing of IT systems, must offer their products fully adapted to the Regulation within a maximum of nine months from the entry into force of the Ministerial Order referred to in the third final provision of this Royal Decree, without prejudice to the mandatory adaptation of systems included in multi-year maintenance contracts according to the deadlines mentioned above. Within a maximum of nine months from the entry into force of the Ministerial Order referred to in the third final provision of this Royal Decree, the service for receiving invoicing records sent by Verifiable Invoice Issuing Systems will be available at the headquarters of the State Tax Administration Agency."

Second final provision.
Safeguard of rank. The modification introduced by Article 3 of this Royal Decree-Law does not alter the regulatory rank of Royal Decree 1007/2023, of December 5, which fully maintains its nature as a regulation, as well as that of its development rules.

Fifth final provision.
Entry into force. This Royal Decree-Law shall enter into force the day after its publication in the “Official State Bulletin”. Given on December 2, 2025.