The General Council of the Colleges of Administrative Managers of Spain has warned that the implementation of mandatory electronic invoicing between businesses and professionals, following the approval of Royal Decree 238/2026 and the processing of the draft order regulating the public electronic invoicing solution, could end up incorporating thousands of small businesses into the Verifactu system.
The collegiate entity insists that we are not facing a mere technological update, but a profound modification of the invoicing scheme and the way companies interact with the Administration.
Along these lines, its president, Fernando Jesús Santiago, has emphasized that "it is not a simple technological change," but a structural transformation in the mechanisms of control and supervision of economic activity, which represents one of the "most important" modifications in recent decades in the daily management of invoices.
NEW MODEL
With the new model, all operations between companies and professionals must be reflected through structured electronic invoices, which will become the reference format in the B2B environment, i.e., in invoices between entities and self-employed individuals.
The General Council also recalls that, since the end of last year, it had been urging companies and professionals to take advantage of the ample period provided to adapt in advance to the new invoicing systems.
However, almost five months later, the scenario continues to be dominated by interpretative doubts, changes in criteria, technical uncertainty, and a high level of ignorance in broad layers of the business fabric about the true scope of these new obligations.
Jesús Santiago has also pointed out that one of the dangers of this type of process is "generating a false sense of distance," emphasizing that it is "precisely there" where administrative managers place one of the greatest concerns associated with the new scheme.
As the General Council warns, the requirement to issue structured electronic invoices will, in practice, lead to the widespread use of Electronic Invoicing Systems (SIF), i.e., the same tools on which the Verifactu regime is based.
Until now, the administrative criterion of the Tax Agency established that Verifactu did not apply to those who issued all their invoices manually, without resorting to a Computerized Billing System. However, it is enough to generate a single invoice through a SIF for the regime to become enforceable.
IMPACT ON SMALL BUSINESSES
With the entry into force of this new system, thousands of small businesses under the modular system, the simplified VAT regime, or the equivalence surcharge (such as cafes, workshops, small shops, printing shops, or stationery shops) could finally be indirectly integrated into Verifactu simply by issuing, even if only occasionally, an electronic invoice to another business owner or professional.
Santiago has warned that many of these small establishments are still "not aware" of what this change could entail, and argues that digitalization should not become a regulatory trap for those who "simply try to work".
The General Council considers it particularly alarming that the overlap of different regulatory calendars, technical requirements, and interpretative criteria is fueling a growing sense of legal uncertainty among businesses and professionals.
For this reason, it calls on the Ministry of Economy, Trade and Enterprise to make use of the exceptions contemplated in article 4 of Royal Decree 238/2026, in order to prevent certain groups from bearing a disproportionate burden.
Finally, the Council recalls that the actual implementation of the system still awaits the definitive approval of the developing Ministerial Order, initially scheduled for October 2026, from which the effective adaptation deadlines for businesses and professionals will begin to be counted.