Updated
Almost nothing of consequence reached the gazette between 23 and 29 September. Rather than pad the issue, we have used it to set out what lands in the last month of the year, because three of the four need work started now and one of them is a valuation date you cannot fix afterwards.
The two draft bills we flagged last week remain open for public comment: the amendment to Organic Law 4/2000 on the rights and freedoms of foreign nationals, and the new Asylum Law. The Ministry of the Interior opened the audiencia e informacion publica from 23 September to 6 October 2026. Nothing has changed in the law in force; what closes is the chance to say anything about it.
The Digital Omnibus on AI was published in the Official Journal on 24 July 2026 and entered into force on 27 July. It deferred the high-risk obligations for standalone Annex III systems from 2 August 2026 to 2 December 2027, and for AI embedded in products covered by EU product safety law to 2 August 2028. Two things land on 2 December 2026 instead: the machine-readable marking duty in article 50(2) for systems already on the market at 2 August 2026, and two new prohibitions added to article 5. The transparency duties in article 50 have applied since 2 August 2026 and the general-purpose model obligations in articles 51 to 56 since August 2025; neither was touched.
Directive (EU) 2024/2853 has to be transposed by 9 December 2026. It applies to products placed on the market or put into service after that date, and Directive 85/374/EEC is repealed with effect from the same day while continuing to govern products placed on the market before it. The new regime extends the chain of liable economic operators and adapts the rules to software, digital products and AI.
Regulation (EU) 2025/2650 of 19 December 2025 amended the EUDR again. It now applies from 30 December 2026 for medium and large operators and traders, with micro and small enterprises given until June 2027. The delay came with simplification of the reporting obligations rather than a change of substance.
Both taxes accrue on 31 December each year and attach to the net worth held on that date. The solidarity tax reaches net wealth above three million euro, allows a deduction only for wealth tax actually paid, and was extended indefinitely by Real Decreto-ley 8/2023 pending a review of wealth taxation. Six regions have since recast their wealth tax relief by reference to it.
Verifactu applies to companies subject to corporate income tax from 1 January 2027 and to the self-employed from 1 July 2027, on the timetable set by article 3 of Real Decreto-ley 15/2025 of 2 December, which amended the fourth final provision of Real Decreto 1007/2023. It is a separate obligation from B2B electronic invoicing, which comes from Real Decreto 238/2026 and whose phased periods only begin once the ministerial order approving the public invoicing solution is published. That order has not appeared. Dates circulating for the B2B tiers are expectations rather than law.
A resolution of the Congress of Deputies of 23 September ordered publication of the convalidation of Real Decreto-ley 23/2026 of 8 September, which adopts urgent fiscal and financial measures for the economic and social reconstruction of La Palma and measures to promote investment by autonomous communities holding budget surpluses and unapplied financing from years before 2026.
The Council of Ministers of 29 September announced a package intended to contain increases in energy bills. At the time this issue closed the instrument had not reached the gazette, so its scope, its beneficiaries and its dates are not yet established. We are not going to summarise a press conference as if it were a decree.