Postponement of SIF/VERI*FACTU

A few days ago, ECIJA announced the imminent entry into force of the VeriFactu system, according to the deadlines that seemed to be established at that time. However, on 2 December, the Council of Ministers approved the postponement of its mandatory implementation, in response to the lack of adaptation by a significant part of the business fabric. The Royal Decree Law formalizing this decision is expected to be published in the Official State Gazette in the coming days, at which point the new entry into force dates will be officially confirmed.

The delay means that, although the basic regulation remains fully in force and the technical requirements of the RRSIF are defined, its mandatory application is postponed to allow more time for adaptation for both companies and self-employed workers.

However, this extension should not be interpreted as a general suspension of the system: new taxpayers who start activity or replace their software after 29 July 2025 must do so with a compatible SIF. Those who purchase billing software for the first time on or after 29 July 2025 must do so with a fully compatible SIF.

This point is especially relevant because manufacturers will not be able to market non-compliant software after this date, which means new users should not purchase, under any circumstances, programs that do not meet the requirements of integrity, traceability, signature, record linking, and other requirements of the RRSIF. The sale or implementation of non-compliant software would constitute a direct infringement attributable to the manufacturer and could place the user in a position of legal risk from the start of their activity. Therefore, even though the mandatory schedule for users has been extended, the market should operate exclusively with already adapted solutions, thus ensuring that any new taxpayer uses a fully valid and secure system from the outset.

This change highlights the importance of specialized technical and legal advice: the regulation remains in effect, but the schedule has changed, necessitating a review of implementation plans to avoid risks and take the opportunity to do so in an orderly manner.

What your company can do now

At ECIJA, we recommend:

• Immediately assess the current state of your billing system: identify if your software meets the Regulation requirements.
• If you have not done so yet, plan ahead for technical adaptations, such as electronic signatures, record generation, traceability, QR codes, data export, etc.
• Take advantage of the postponement to train personnel, review contracts with software providers, or evaluate new providers, and ensure an orderly transition.
• Stay informed about regulatory developments and prepare the necessary documentation (audits, certificates of compliance, technical adaptations, etc.).

The postponement of the VeriFactu system represents a practical relief for many companies and self-employed workers, but does not cancel the obligation. The new schedule allows for a more reasonable transition. At ECIJA, we will continue to provide legal and technical support throughout this process, both to software manufacturers and users, to ensure regulatory compliance with legal certainty and operational efficiency.

Informative note prepared by the Data Protection Department of ECIJA Madrid.