Verifactu and mandatory e-invoicing in Spain: what applies to your company now.
Two separate obligations, two different laws, two different deadlines — and almost every foreign-owned Spanish company confuses them. One of them is already in force for small and medium companies. This is the working explanation of which is which.
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. A foreign founder who reads that "electronic invoicing has been delayed to 2027" and concludes that nothing is required yet has drawn precisely the wrong conclusion: the obligation that has actually taken effect is the other one.
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".
| 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 |
| Large companies from | 1 January 2026 | Phased after entry into force |
| SMEs and autonomos from | 1 July 2026 | 1 October 2027 (deferred) |
| 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 |
"Electronic invoicing has been postponed to 2027."
True of the Crea y Crece B2B regime. Not true of Verifactu, which has applied to small and medium companies since 1 July 2026. If your Spanish SL is invoicing today with a spreadsheet, a generic template or non-Spanish software that was never adapted, that is the exposure to address first.
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.
- 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 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 happens if we are not compliant right now?
Running a Spanish company properly.
One deadline was postponed. The other one already arrived.
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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