Board
One date, not two
The roadmap follows the gazette. The Ministry note is watched, not executed.
Software that invoices for thousands of businesses. And the legal date is not the one in the press note.
What the vendor and the accountancy firm must be able to show before 1 January 2027, and how one partner carries billing, banks and tax.
Technical analysis
Globodain's reading
The legal date for companies is still 1 January 2027: the delay to October 2028 is announced, not published.
Official gazette, RD 1007/2023 | Ministry of Finance, 5 Oct 2026
Calendar
Two dates. Only one is law. The other is a one-page note.
What is in the official gazette and what the Ministry has said it intends to change. A note does not amend a regulation.
29 Jul 2025
The vendor was already due
Nine months from the technical order: the producer had to offer an adapted system.
RD 1007/2023, final provision 4 | Order HAC/1177/2024
5 Oct 2026
The Ministry announces a delay
A note intends to move the pending duties to October 2028. It is not a statute.
Ministry of Finance, note of 5 Oct 2026
1 Jan 2027
Companies, per the gazette
Corporate-tax payers must have the system adapted before that day.
RD 1007/2023, final provision 4 (RDL 15/2025), art. 3.1.a
1 Jul 2027
The self-employed and the rest
Everyone else in article 3.1 must have the system running before that date.
RD 1007/2023, final provision 4 (RDL 15/2025)
The challenge
The client is asking today even if the note talks about 2028.
What this profile pays for today
- 01The gazette date and the Ministry note do not match
- 02Every version of the software needs a declaration of responsibility
- 03Chained records, a hash and invoice retention
- 04Accountancy firms with hundreds of clients on one platform
- 05Banks, the shop and tax on the same data
- 06The client's question does not wait for the delay
What they ask
What the firm asks before migrating one more client.
The question from the practice or the sole trader, the article behind it, and what a technology partner leaves ready.
What they ask
The rule
What we prepare
01Is the invoice chained?
RD 1007/2023: integrity, fingerprint and retention
What we prepare |The issue and cancellation records, checkable
02Where is the declaration?
Art. 13: visible in the system, on every version
What we prepare |The declaration findable by the client and the tax agency
03Which date do I build for?
Final provision 4: 1 Jan 2027 and 1 Jul 2027, still in the gazette
What we prepare |The product ready for the legal date, not for the note
04Who sees the invoices?
GDPR: the business is controller, the software is processor
What we prepare |The firm's access, processors and retention
What we propose
One technology partner for the product and for the firm.
The same counterpart covers the billing record, the banks, the accountancy firm and the evidence the client asks for.
Accountancy firms
One version for the whole practice
Opening a new client does not reopen the design of the record.
Technical team
Capacity that adds
Reinforcement on records, data and integrations, without replacing the team.
Expected impact
More practices served with the same team.
What changes when the record, the declaration and the bank connections stop being rebuilt per client.
×1.7
clients the product can serve by the end of the period, versus staying without a partner
−23 pts
of technical time that returns to product and accountancy firms
6 → 1
technical areas, one counterpart
Illustrative scenario, not a forecast. Index 100 = clients the product can serve in Nov 2026. Assumption: freed time goes back to product and to signing accountancy firms.
Its market
The same software, three clients sole trader, company and accountancy firm.
The dates are from the gazette and the Ministry. The scale is one product in the sector, cited with its source.
1 Jan 2027
companies must have the system adapted; everyone else, before 1 July 2027
Official gazette, RD 1007
Oct 2028
the Ministry announces a delay that is not yet published in the gazette
Ministry of Finance
1,266
accountancy firms run more than 21,000 companies on one product in the sector
Forbes, 21 Sep 2026
Firms in the sector
- QuipuBilling, tax and banks. It marks January and July 2027
- AnfixBilling and accounting with a Verifactu mark, also for accountancy firms
- TS FacturasOnline billing (formerly Billin), adapted to Verifactu
- HoldedCloud billing, accounting and banks, with Verifactu included
A product that bills for the sole trader, the company and the firm that serves both has more technical surface than one that only emits a PDF.
How we would solve it
A continuous rhythm, not a patch for every rule.
Each version of the software ships with the declaration and the record in place.
Phase 01
Diagnosis
Records, declaration, banks, the firm's access and data.
Phase 02
Audit
A report the board and the practice can both show.
Phase 03
Implementation
We fix it with their team, without replacing it.
Phase 04
Watch
A warning the day the delay, if it comes, is published.
Benefits and advantages
What this profile gains before January.
01
One working date
The team builds against the gazette and watches the note, without mixing them.
02
The declaration at hand
Every version can be found, as article 13 requires.
03
The firm does not reopen the design
A new accountancy practice joins the same platform.
04
Banks on the same data
The movement and the invoice do not live in two places.
05
One partner
Billing, tax, treasury and accountancy firms, one relationship.
06
The team on the product
Technical time goes back to sign-ups and the roadmap.
Scope and limits
So it is clear from day one.
What we bring
- Technical audit, implementation and continuous watch
- A report of findings and priorities
- A stable counterpart, not a one-off vendor
What we do not do
- We do not certify regulatory compliance
- We do not sign the vendor's declaration of responsibility
- We do not replace tax advice: we complement it
The declaration of responsibility is signed by the producer of the system. Tax advice belongs to third parties. We provide technology support: audit, implementation and watch.
Why Globodain
Capabilities that apply to billing software like this.
Scope note: mentioning regulated environments describes applicable capabilities, not a proven track record in billing software.
- 01
Records
Issue, cancellation, fingerprint and retention, checkable.
- 02
Declaration
Every version findable, as article 13 requires.
- 03
Data
The firm's access, processors and retention.
- 04
Integrations
Banks and collections on the same data as the invoice.
- 05
Technical audit
A report the practice can show its client.
- 06
Watch
A warning the day a note becomes the gazette.
Does your case look like this profile? We analyse it with you.
This analysis was built from public sources on the sector. If yours looks similar, Rubén Ayuso will analyse it with you and prepare one for your case.
A study built from public sources on the sector. It does not describe a specific company and was not prepared with one. The companies named are examples: it implies no relationship and no involvement on their part. It is not legal advice and not a contractual commitment.
