01
AI and tech2 August 2026Act now
AI Act transparency rules started, and they are not just for high-risk systems
Article 50 of the AI Act became applicable on 2 August 2026. Interactive systems must tell people they are talking to a machine. Synthetic audio, images, video and text must be marked as artificially generated. Content that looks or sounds like a real person must be labelled even where no deception was intended and no real individual is depicted. None of this depends on your system being high-risk: it applies to generative AI across the board.
Who this touchesAny company with a customer-facing chatbot, an AI tool generating published content, or a product that produces synthetic media. The high-risk timetable that was deferred to 2027 has nothing to do with this.
Audit where generative AI touches your customers, then fix the disclosure. Systems placed on the market before 2 August 2026 get until 2 December 2026, and only for the marking and detection obligation.
02
AI and tech27 July 2026Diarise
The AI Act simplification package is now binding law
Regulation (EU) 2026/1744 entered into force on 27 July 2026, which converts the much-discussed deferral into something you can plan against. High-risk obligations for standalone Annex III systems move to 2 December 2027, and AI embedded in products already regulated under Union harmonisation law moves to 2 August 2028. What did not move: general-purpose AI model obligations, live since August 2025, and the Article 50 transparency rules above.
Who this touchesProviders and deployers of high-risk AI systems who were working to an August 2026 date.
Rebase the compliance plan on the new dates, and check that nobody on the team has quietly concluded that the whole Act was postponed.
03
Company and market accessSince 1 July 2026Act now
Crypto firms trading on the old Spanish registration no longer have a basis to do so
Full CASP authorisation from the CNMV became the only route from 1 July 2026. The earlier registration with the Banco de Espana, which covered a narrower set of activities, stopped being sufficient. Very few authorisations had been granted by mid-year, largely because thin applications are returned rather than cured, and preparation plus review realistically runs six to fifteen months.
Who this touchesAny firm providing crypto-asset services into Spain, and any non-EU firm that assumed the Spanish register was a light-touch entry point.
If you are operating on the old registration, treat that as the urgent item. If you are planning entry, note that the applicant must be established in Spain, so incorporation comes first rather than alongside.
04
TaxCorrectionAct now
Verifactu is not in force, whatever you were told in July
We are flagging our own error alongside a widespread one. Real Decreto-ley 15/2025 deferred Verifactu by a year: 1 January 2027 for corporate income tax payers, 1 July 2027 for autonomos and everyone else. The superseded dates of January and July 2026 are still quoted on a very large number of Spanish advisory sites, and our own guide carried them until this week. If somebody told you in July that you were already in breach, check their source.
Who this touchesEvery company and self-employed person invoicing from software in Spain. Those already reporting under the SII, and the Basque Country under TicketBAI, are outside Verifactu entirely.
Do not pay for an emergency migration you do not need. Do use the year: ask your software provider in writing when the system will be certified, and count your invoice streams including the manual ones.
05
Company and market accessCounting down to 9 December 2026Diarise
Strict product liability reaches software and AI, and it reaches representatives
The new Product Liability Directive applies to products placed on the market after 9 December 2026, with transposition due by the same date. It extends no-fault liability to software and AI-enabled products, and it places importers and authorised representatives into the liability chain where the manufacturer sits outside the EU.
Who this touchesNon-EU manufacturers selling into the EU, and anyone acting as their EU representative or importer.
If you hold or are considering a representative mandate, establish now whether your insurance responds to strict product liability as well as professional negligence. They are different insuring clauses.
06
Tax20 and 31 August 2026No action
The August filing dates, for the record
Monthly withholding returns for July fell due on 20 August, and the monthly Modelo 303 for July on 31 August, alongside the other monthly VAT forms. Certain INTRASTAT declarations fell on 12 August.
Who this touchesCompanies filing monthly. Quarterly filers had nothing in August.
Nothing, if your adviser handled it. Worth confirming that a holiday month did not swallow a monthly filing.
Nothing in this group in this issue.
Each item links to its source. We summarise; we do not replace the official text, and Spanish implementation dates have moved more than once. Nothing here is legal or tax advice for your situation.