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 (IS) must use VeriFactu-certified invoicing software.
Self-employed workers (autónomos) and remaining taxpayers using invoicing software must comply — this is the date most sources treat as VeriFactu's true universal deadline.
Once the implementing order is published, businesses with turnover above €8 million must comply within 1 year, and all other businesses and autónomos within 2 years. A public consultation on the order completed in 2026, but as of mid-2026 it remained pending.
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.