Verifactu and mandatory e-invoicing in Spain: what applies, and from when.
Two separate obligations, two different laws, two different clocks — and almost every foreign-owned Spanish company confuses them. Neither one binds you today: Verifactu was deferred by a year, and the B2B regime is waiting on a ministerial order. This explains which is which, and what the remaining window is actually for.
Spain is in the middle of the most significant change to business invoicing in a generation, and it is arriving in two waves that are routinely mistaken for one. Both have now slipped, which has produced a second mistake to sit alongside the first: founders who conclude that because nothing binds them today, nothing needs doing. The work these rules require is software and process work, and it does not compress into the last month.
The distinction matters because the two regimes have different legal sources, different affected parties, different technical requirements and different penalties. A typical Spanish company will end up complying with both, in parallel, on separate timetables.
The two obligations, side by side.
Verifactu — how your software must behave
Your billing system must produce records that are traceable, unalterable and verifiable by the tax authority. It governs the software, and it applies to invoices you issue to anyone, including consumers. Source: anti-fraud legislation and its implementing regulation.
B2B e-invoicing — how invoices are exchanged
Invoices between businesses and professionals must be issued and received in a structured electronic format, with status reporting. It governs the exchange, and it applies only to B2B. Source: Ley 18/2022 "Crea y Crece", developed by Real Decreto 238/2026.
| Verifactu | B2B e-invoicing | |
|---|---|---|
| What it regulates | Your invoicing software and its records | The format and exchange of B2B invoices |
| Who is covered | Companies and autonomos issuing invoices | Businesses and professionals, B2B transactions |
| Applies to B2C? | Yes | No |
| Companies from | 1 January 2027 | 12 months after the ministerial order, above €8M turnover |
| Autonomos and the rest from | 1 July 2027 | 24 months after the ministerial order |
| Who is out of scope | Companies already under the SII, and the Basque Country under TicketBAI | B2C invoicing entirely |
| Core requirement | Unalterable, traceable, hashed records; optional real-time submission to the AEAT | Structured format, delivery, and reporting of invoice status |
| Reported penalty exposure | Up to €50,000 per year for non-compliant software | Up to €10,000 for refusing to issue or accept |
Two instruments, and only one of them gave a date.
Real Decreto-ley 15/2025 moved Verifactu by a year, to 1 January 2027 for corporate income tax payers and 1 July 2027 for everyone else. That is a fixed calendar date and you can plan against it. Real Decreto 238/2026, in force since April 2026, developed the B2B regime but did not start its clock: the countdown runs from a ministerial order regulating the public invoicing platform, and only then do the 12-month and 24-month phases begin. Anyone quoting you a firm B2B date today is quoting an expectation, not a rule.
What Verifactu actually requires of your system.
Verifactu is not a filing you submit. It is a set of properties your invoicing software must have, enforced by making non-compliant software itself unlawful to use and to sell.
There are two operating modes. In Verifactu mode, records are transmitted to the tax authority automatically as invoices are issued, which relieves the company of certain retention duties. In non-Verifactu mode, records stay with the company but must meet stricter integrity, signature and retention requirements and be available on request. Most standard commercial software defaults to the first.
- Is the software declared compliant? Providers must issue a responsible declaration confirming the system meets the requirements
- Which mode does it use — automatic submission or compliant local retention
- Does it cover every invoice stream — including e-commerce, POS, subscriptions and any secondary system
- Do invoices carry the QR code and required identification
- How are corrections handled — rectifying invoices, not edits
- Is your foreign group ERP in scope for the Spanish entity's invoicing, and has it been adapted
- Who retains the records and for how long
The trap specific to foreign-owned companies.
A Spanish subsidiary of a foreign group usually invoices from the group's existing ERP or billing platform, configured for the parent's home market. That system may be excellent and entirely lawful where it was built — and still fail Spanish requirements, because the requirements are about record integrity in a specific technical form that non-Spanish vendors have had no reason to implement.
Group ERP, unmodified
Invoices issued from headquarters' system for the Spanish entity, no Spanish adaptation module, no QR code, editable records, and nobody in the group aware the Spanish rules reach the software rather than the filings.
Adapted module or local system
Either a Spain-certified module within the group ERP, or a compliant Spanish invoicing system for the local entity, with a provider declaration on file and every invoice stream covered.
The same logic will repeat in 2027 with B2B e-invoicing, which adds a structured-format and status-reporting requirement that group systems will again need to be adapted for. Companies that resolve the invoicing stack properly now generally find the second wave is a configuration change rather than a project.
Invoicing system, filings and deadlines as one file.
We check whether your Spanish entity's invoicing meets current requirements, fix what does not, and carry the ongoing filing calendar — so the 2027 wave is a configuration change, not an emergency.
The sequence to follow.
What the window is for.
Verifactu binds companies from 1 January 2027. That is close enough to plan against and far enough that nothing about it is urgent this week — which is exactly the condition under which it gets forgotten until December. The work is not filling in a form; it is changing the system you invoice from and the habits of the people who use it.
Because the software was not ready, not because the rules softened.
Two reasons were given for moving the dates: developers needed more time from the publication of the final technical specifications, and the government wanted Verifactu and the B2B regime to land in an order that did not force small businesses to change systems twice in one year. The technical requirements themselves — unalterable chained records, hashing, the QR code on every invoice — were not relaxed.
A year of runway, used deliberately
Migrate while the stakes are zero. Companies that switch in 2026 get to discover their edge cases — credit notes, partial refunds, multi-currency, the odd manual invoice — without a penalty regime attached to the discovery.
"It moved once, it will move again"
It may. It also may not, and the cost of being wrong is asymmetric: penalties reported at up to 50,000 euro a year attach to using or holding non-compliant invoicing software, and your accountant will be fully booked in the last quarter before the date.
Some companies are outside Verifactu entirely.
Businesses already reporting under the SII immediate information supply regime are out of scope, as is the Basque Country, which runs TicketBAI on its own timetable. If either describes you, the Verifactu date is not your date — and confirming that now saves paying for a migration you never needed.
- Verifactu
- The regime governing invoicing software integrity, and the name of the mode in which records are sent to the AEAT automatically.
- SIF
- Sistema informatico de facturacion — the invoicing system the rules apply to.
- Ley Crea y Crece
- Ley 18/2022, which introduces mandatory structured B2B electronic invoicing between businesses and professionals.
- Factura rectificativa
- Rectifying invoice — the only lawful way to correct an issued invoice under an unalterable-records regime.
- Declaracion responsable
- The responsible declaration a software provider issues confirming its system meets the requirements. Ask for it in writing.
- AEAT
- Agencia Estatal de Administracion Tributaria — the Spanish tax authority.
- Factura simplificada
- Simplified invoice, used for smaller consumer transactions; still within the software requirements.
Is Verifactu in force right now?
So can we do nothing until December 2026?
Is Verifactu the same as mandatory electronic invoicing?
Can we keep invoicing from our group's ERP abroad?
What if we only invoice a handful of clients?
Do these rules apply if our company is dormant?
What are the penalties once it does apply?
Running a Spanish company properly.
Both deadlines moved. Neither obligation went away.
Book a free call ↗Alexander Baranov
Seventeen years designing and delivering cross-border corporate structures — incorporation, tax, holding, banking and market entry — for founders and companies expanding into Spain and the EU. Author of professional books on entering the Spanish market.
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