There is a very widespread confusion between Verifactu and mandatory electronic invoicing. They are two completely different obligations, with different legal bases, objectives and timelines.
Verifactu regulates the software that generates invoices — how they are created, recorded and stored internally. Electronic invoicing, on the other hand, regulates the format and delivery of the invoice to the client — how the document is transmitted between companies. They are two different layers of the same chain, but with completely different legal bases, objectives and timelines.
Verifactu originates from the Anti-Fraud Law (Law 11/2021) and is developed in Royal Decree 1007/2023. Its objective is to prevent the manipulation of invoicing records, ensuring that no invoice can be altered or deleted without leaving a trace. The deadlines are firm: January 2027 for companies and July 2027 for freelancers.
Mandatory electronic invoicing is based on Law 18/2022 (Ley Crea y Crece). Its objective is to digitise B2B commercial relationships, eliminating paper invoices in business-to-business transactions. The specific deadlines are still pending regulatory definition.
Many believe they already comply with Verifactu because they send electronic invoices. But no — Verifactu refers to the internal system that generates and records invoices, not the delivery format.
Another common mistake is thinking that if you comply with Verifactu, you do not need electronic invoicing. They are independent obligations and you will need to comply with both when mandatory electronic invoicing comes into force.
Some also believe that electronic invoicing is already mandatory, but it is not yet mandatory across the board. The regulation with specific deadlines is still being developed.
Right now, your priority should be Verifactu. The deadlines are firm (2027), the regulations are fully developed and the AEAT system is already operational. Mandatory electronic invoicing will come later.
CokuApp complies with Verifactu today and will be ready for mandatory electronic invoicing.