The news of the extension of Verifactu’s deadlines has been received by many companies and freelancers with a sigh of relief, but at Ruiz & Asociados we observe this “respite” with caution. Although the obligation to submit invoices to the AEAT has been moved to 2027, the legal framework that prohibits the use of non-certified software (capable of altering or deleting records) is already fully in force under the Anti-Fraud Law. Ignoring technological migration this year is not only losing a competitive advantage, but also exposing oneself to sanctions that the Treasury will not hesitate to apply if it detects systems that do not guarantee the integrity and traceability of data.
The New Calendar: Reality vs. Expectation
It is essential to understand the dates set by Royal Decree-Law 15/2025. After the latest update, the automatic sending of registrations to the Tax Agency will be mandatory on 1 January 2027 for commercial companies and on 1 July 2027 for the rest of the self-employed and professionals. However, 2026 is the year of critical transition.
Waiting until the last quarter of this year to implement certified Verifactu software is an unacceptable operational risk. A rushed migration of billing systems often results in data loss, errors in the billing series, and a learning curve that overwhelms the company’s administration. The extension is not an invitation to inaction, but rather a window of opportunity for businesses to carry out an orderly and secure transition.
Why migrate to Holded now (and not in 2027)
As Gold Partners of Holded, in our firm we have verified that digitalization is not a switch that is turned on and off; it is a process. Using leading platforms that already meet Verifactu’s technical requirements (electronic signature, record chaining or hashing, and QR code generation) offers three immediate advantages:
- Total Legal Security: Holded guarantees the integrity of records, complying with Article 29.2.j) of the General Tax Law from day one. You are protected against an inspection even before submission becomes mandatory.
- Automation and Control: Verifactu requires that each invoice be linked to the previous one. Doing this manually or on outdated systems is impossible. Holded does it in the background, without your team losing a second.
- Synchronization with your accounting firm: By working on a shared cloud with Ruiz & Associates, we eliminate the need to handle paper or PDF invoices. We monitor the integrity of your Verifactu records in real time, detecting any anomalies before they become tax issues.
Penalties: Too high a cost due to Excel nostalgia
The Treasury has been very clear: from 2027, invoices issued in non-certified systems (such as Excel or Word) will simply not have legal validity to deduct expenses. But fines for possessing or using “dual-use” software or software not adapted to the regulation can reach 50,000 euros per financial year.
In 2026, the Labor Inspectorate and the Tax Agency are conducting joint campaigns to verify companies’ digitalization efforts. Not having a traceable migration plan to a system like Holded is, in the eyes of the tax authorities, a red flag of tax risk.
The opportunity of “Create and Grow”
We mustn’t forget that Verifactu is aligned with the Law Creates and Grows, which will mandate electronic invoicing between businesses (B2B). Getting ahead today with robust software means that when electronic invoicing becomes commonplace, your company will already have automated processes in place.
At Ruiz & Associates, with our more than three decades of experience, we’ve seen how companies that lead the way in regulatory change are the ones that best weather crises. Digitalization isn’t just about “complying with the tax authorities”; it’s about professionalizing your business, knowing your margins in real time, and protecting your personal assets from business contingencies.
Conclusion: Time is your greatest asset
The Verifactu extension is a golden opportunity to streamline your administrative processes. Don’t let the false sense of time lead to a collapse in December. Implementing Holded under our technical supervision is the best investment you can make in the first quarter of 2026.
Reservation note: The aforementioned deadlines are subject to the final publication of the ministerial orders for technical development. However, the software architecture must be ready months in advance to ensure full compatibility.
Is your current billing system compliant with the Anti-Fraud Act?
At Ruiz & Asociados we help you to migrate to Holded in complete security and without interrupting your activity. Contact us today for an audit of your systems and prepare for the smooth future.


