Country deep dive
Three distinct regimes — B2G, SII, and now VeriFactu — have accumulated over a decade. Crea y Crece's B2B mandate is the newest piece, and the one still missing its implementing detail.
Invoices to Spanish public bodies must be submitted in Facturae XML format via the FACe platform — a paper invoice or simple PDF is not valid and won't be processed.
Large taxpayers and monthly filers must send sales and purchase ledgers to AEAT within 4 days, replacing quarterly block reporting with near-real-time visibility. Businesses in SII are outside VeriFactu's scope.
Establishes the legal framework mandating structured B2B e-invoicing — but as a framework law, leaving the technical detail and exact start dates to a future implementing ministerial order.
Sets out the technical requirements for invoicing systems (Reglamento de requisitos de los sistemas informáticos de facturación) underpinning VeriFactu: chained cryptographic hashes, secure timestamps, and electronic signatures to prevent undetected record alteration.
Businesses subject to Corporate Income Tax must use VeriFactu-certified invoicing software (RRSIF) that guarantees the integrity, traceability and immutability of billing records sent to the Agencia Tributaria (AEAT).
The VeriFactu obligation extends to all remaining taxpayers required to keep billing records, including the self-employed and other professionals subject to Personal Income Tax.
Structured B2B e-invoicing becomes mandatory for large businesses under the Crea y Crece law, exchanged via private platforms (with a mandatory copy to the state platform) or the free public solution (SPFE), running alongside VeriFactu.
The B2B e-invoicing mandate extends to SMEs, sole traders and all other VAT-registered businesses, completing Spain's dual-track e-invoicing reform.
The single most important thing to understand about Spain: VeriFactu is not an invoice format at all — it's a requirement on the software that produces your invoices.
A VeriFactu-compliant invoice can still be a plain PDF in appearance — what matters is the underlying record's integrity, not its visual format.
This has applied for over a decade and isn't changing — treat it as the stable baseline while VeriFactu and Crea y Crece both continue to develop.
Don't build a specific B2B schema assumption into production systems yet — Facturae and UBL are both plausible, and the order will settle it.
If you're a business rather than a software vendor, your job is confirming your provider has filed this declaration — not filing it yourself.
Spain runs three parallel systems that don't all talk to each other the same way — knowing which one applies to you matters as much as the technical detail.
These are mutually exclusive — if you're in SII, you are explicitly out of VeriFactu's scope. Don't build for both.
Both modes satisfy the legal requirement — the choice is about your operational preference for live reporting versus retained, tamper-evident local records.
The B2B e-invoice network does not send invoice content to AEAT the way VeriFactu can — it's a separate exchange-and-status-tracking layer between trading partners.
This is a materially stronger inspection power than most EU e-invoicing regimes grant — plan your system architecture assuming AEAT can and will exercise it.
Because two reforms are running on different tracks, your readiness checklist genuinely splits in two.
Check whether you're a large taxpayer or monthly filer already in SII — if so, VeriFactu doesn't apply to you at all.
Ask your invoicing software provider to confirm they've filed the declaración responsable for your specific version — this is their obligation, not yours, but you need the assurance.
Corporate taxpayers: decide real-time AEAT transmission vs. local hash-chained storage before 1 January 2027. Autónomos and others: the same decision applies before 1 July 2027.
If you already invoice public bodies, confirm Facturae 3.2.1/3.2.2 generation and FACe submission remain in good working order — this obligation isn't changing.
Once published, your compliance clock starts immediately — 1 year if you're above €8 million turnover, 2 years otherwise. Don't wait until publication to start evaluating platforms.
Plan for 4-year tax retention and 6-year commercial retention separately, and notify AEAT if any records are hosted abroad.
Spain's penalty structure scales with the severity of the underlying issue — a formatting slip and outright fraud sit at opposite ends of a very wide range.