Expats do not necessarily have easy access to Spanish professional association commentaries so we thought this message from the AEDAF (Asociación Española de Asesores Fiscales) might be of interest and complete the picture of how negatively this delay has been regarded by the Spanish professional community.
We received comments to our recent email circular about this postponement to the effect that we should not be surprised as all Governments are incompetent, but we believe this saga goes to the very extreme of administrative incompetence. Several days have passed since the annnouncement but we remain astonished, indeed stunned, and struggling to reconcile our work and that of our clients, given that there are so few working days left in the year.
We publish below an English translation of the commentary published Association on the 4th December, in its entirety.

Dear members:
We would like to share our Association’s opinion regarding Royal Decree-Law 15/3025 of December 2, which delays the entry into force of VERI*FACTU by one year:
While it is true that many companies, SMEs, and self-employed workers have welcomed this extension with relief, the postponement just one month before its entry into force sends a deeply negative message to society and the business community as a whole. A reform that has been announced for years cannot be delayed at the last minute without revealing a lack of planning on the part of the Administration itself.
In recent months, thousands of companies, SMEs, and self-employed workers—guided and advised largely by tax professionals—have tried to adapt to obligations whose scope, functioning, and operation still raised significant doubts for many sectors and, more worryingly, even for the Administration itself. In many cases, these companies had already made significant investments, adapted their billing systems, contracted technological solutions, and participated in training courses with the intention of complying with the new regulations on time.
The announced postponement is an implicit acknowledgment that the preparation has not been sufficient to ensure an orderly, gradual, and technically sound implementation. A tax modernization of the magnitude of Verifactu requires realistic anticipation, well-designed impact assessments, and a firm timetable that allows companies, professionals, and economic sectors to adapt with time, certainty, and knowledge.
Modifying such a significant obligation at the last minute directly affects companies’ confidence in regulatory stability and raises doubts about the predictability of tax policy. In an already complex economic environment, legal certainty and institutional clarity must be essential pillars.
At AEDAF, we would like to emphasize that this is not just a temporary adjustment, but a question of method. Tax reforms must be designed and implemented with strategic rigor, realistic timelines, and effective dialogue with the sectors affected. Only in this way is it possible to avoid improvisation, ensure a serious assessment of the impacts—especially on SMEs and the self-employed—and provide companies with clear, coordinated, and timely communication. Similarly, it is essential to reinforce the commitment to legal certainty, without which it is impossible to preserve confidence and economic stability.
Added to all this is a particularly worrying element: the message that this decision sends to citizens and the business community. Companies that have devoted time, resources, and effort to adapting in time now feel discouraged, while those that have not undertaken the necessary preparation may perceive that this lack of foresight is, in practice, rewarded. This effect is deeply discouraging and sends an unequivocally negative signal about the future: “don’t get ahead of yourself, don’t invest, don’t plan too much, because the rules may change at the last minute.” This message undermines confidence, introduces uncertainty into decision-making, and raises reasonable doubts as to whether situations like this could happen again.
For all these reasons, AEDAF insists on the need for a more strategic and coherent tax policy that respects the efforts made by companies and professionals. Only through solid planning, rigorous evaluations, and clear institutional communication will it be possible to restore confidence and ensure effective and sustainable regulatory modernization.
AEDAF reiterates its willingness to collaborate with the Administration to ensure that the definitive implementation of Verifactu is carried out with all the necessary guarantees and with the time required for companies, professionals, and economic sectors to adapt appropriately.
We hope you find this information useful.
Best regards.




