Verifactu and e-invoicing in Spain: dates and rules

What is Verifactu and who must comply?

Verifactu is the informal name for the Regulation approved by Royal Decree 1007/2023, which sets requirements for invoicing software systems (SIF): every invoice must generate a chained billing record with a hash and a QR code. It matters because, after the latest delay, companies must comply before 1 January 2027 and all other businesses before 1 July 2027.

The regulation develops Article 29.2.j) of the General Tax Law, added by the anti-fraud law (Law 11/2021), which requires invoicing software to guarantee the integrity, preservation, accessibility, legibility, traceability and unalterability of records. It does not change the substantive invoicing rules, which remain in the VAT Law and the Invoicing Regulation (Royal Decree 1619/2012): it changes how the program that issues invoices must behave.

Verifactu should not be confused with e-invoicing. The Spanish Tax Agency (AEAT) says it expressly: billing records do not contain all the invoice information and are never electronic invoices. A business can keep issuing paper or PDF invoices with a Verifactu system, and mandatory B2B e-invoicing is a separate obligation with its own timetable.

Verifactu deadlines after the delays, as of September 2026

The timetable has moved twice. Royal Decree-law 15/2025 of 2 December extended the adaptation period, and the AEAT's frequently asked questions, updated on 21 July 2026, set out the dates in force. Software producers and sellers had nine months from the entry into force of Order HAC/1177/2024 to offer adapted products, a period that ended on 29 July 2025.

Until those dates, using an adapted system is voluntary. It is wise not to leave it to the deadline: the change affects numbering, the way invoices are corrected, the invoice layout with its QR code and the training of administrative staff, and all of it should be tested with real invoices before the compulsory date.

• Corporate income tax payers: adapted systems running before 1 January 2027
• All other obliged persons (self-employed individuals under personal income tax, pass-through entities and others): before 1 July 2027
• Software producers: adapted products since 29 July 2025, with a responsible declaration
• The Canary Islands, Ceuta and Melilla are included; references to VAT are read as IGIC and IPSI

Technical requirements: registration, cancellation, hash and QR

When each invoice is issued, full or simplified, the system generates a registration billing record (registro de alta) with the mandatory data of Article 6 of the Invoicing Regulation, plus security data, the system's identity and the date and time. Each record includes a hash calculated with part of the immediately preceding record, so an omission or an alteration breaks the chain and becomes visible.

If an invoice was issued by mistake, the system does not delete it: it generates a cancellation billing record (registro de anulación). If an amount or a detail of the transaction must be corrected, a corrective invoice (factura rectificativa) is issued, which produces its own registration record. The record format and layout are the same for every system and are specified in the annex to Order HAC/1177/2024.

• A registration billing record for every invoice issued
• A cancellation billing record, never a deletion
• A hash chained to the previous record
• A QR code on every invoice, full and simplified
• The legend Factura verificable en la sede electrónica de la AEAT or VERI*FACTU in the real-time mode
• Electronic signature of the records and an event log in the NO VERI*FACTU mode

VERI*FACTU mode or NO VERI*FACTU mode

The regulation allows two ways to comply. In VERI*FACTU mode, the system sends each registration record to the AEAT when the invoice is issued; the customer can scan the QR code with the AEAT app and check that the invoice is on file. In NO VERI*FACTU mode, the records are kept in the system itself, electronically signed, together with an event log, and are sent to the authority when it asks for them.

The choice has practical effects. Real-time sending simplifies record keeping and lets the business view the list of invoices issued in the AEAT's online office, and even those received from suppliers that also use VERI*FACTU, which helps with VAT returns and the invoice register. Local storage requires more of the business's own controls: signatures, the event log, backups and the ability to export records on request.

For small businesses without their own system, the AEAT offers a free application in its online office, in VERI*FACTU mode, with limits: full invoices only, no simplified invoices, and a single recipient per invoice.

Who is outside Verifactu: SII, TicketBAI and Navarre

The AEAT sums up the scope with a rule of four NOs. Obliged persons are businesses and professionals established in Spain that issue invoices and that do NOT invoice only by hand, are NOT under the Immediate Supply of Information system (SII), do NOT have their tax domicile in the Basque foral territories or Navarre, and do NOT hold a non-application ruling.

The SII is compulsory for taxpayers who file VAT monthly: large companies with turnover above EUR 6 million, VAT groups, businesses in the monthly refund register (REDEME) and holders of fuel tax warehouses. They send invoice register details within four days, excluding Saturdays, Sundays and national holidays, and do not file forms 347 or 390. Any business can opt into the SII voluntarily, and those who do are outside Verifactu.

In Álava, Bizkaia and Gipuzkoa, TicketBAI applies, the foral system with its own rules in each territory, and Navarre applies its own regulation. What decides is the tax domicile under the Economic Agreements, not where the service is performed: a company domiciled in Madrid with a shop in Bilbao remains under Verifactu.

Mandatory B2B e-invoicing: the Crea y Crece law and RD 238/2026

Law 18/2022 on business creation and growth (Crea y Crece) created the obligation to issue and receive electronic invoices between businesses and professionals, chiefly to monitor payment terms and late payment. Its implementing rules came with Royal Decree 238/2026 of 25 March, published in the Official State Gazette (BOE) on 31 March 2026 and in force since 20 April 2026.

Effective application counts from the entry into force of a ministerial order developing the AEAT's public e-invoicing solution: twelve months later for businesses whose turnover exceeded EUR 8 million in the previous year, and twenty-four months later for everyone else. As of September 2026 that order had not been published in the BOE, so the obligation does not yet have an effective date; the public solution must be available at least two months before it.

Invoices will follow the European standard EN 16931 in CII, UBL, EDIFACT or Facturae syntax, and Peppol BIS messages are accepted. A business that does not issue through the public solution must send it a faithful copy in UBL at the same time, and private platforms must interconnect with each other.

• The recipient tells the issuer about commercial acceptance or rejection and its date
• The recipient tells the issuer about full payment and its date
• Deadline to report statuses: four calendar days, excluding Saturdays, Sundays and national holidays
• First twelve months for businesses above EUR 8 million: send a PDF with the e-invoice unless the recipient expressly agrees otherwise
• Up to twelve extra months for individuals and pass-through entities with turnover up to EUR 8 million to report invoice statuses

Worked example: a Verifactu invoice and its journal entry

A consultancy with its tax domicile in Valencia invoices a company on 12 February 2027 for a service with a taxable base of EUR 5,000. VAT at 21 percent is 1,050 and the customer withholds 15 percent on account of personal income tax, which is 750. The invoice total is 5,000 + 1,050 = 6,050 and the amount to collect is 6,050 - 750 = 5,300. On issue, the system generates the registration record with its chained hash and prints the QR code on the invoice. The entry under the Spanish chart of accounts (PGC) is: Dr 430 Customers 5,300 / Dr 473 Tax authority, withholdings and payments on account 750 / Cr 705 Services revenue 5,000 / Cr 477 Output VAT 1,050. Debits and credits both total 6,050.

If the customer disputes EUR 1,000 of the base, the fix is not to edit the invoice: a corrective invoice is issued for -1,000 base, -210 VAT and -150 withholding, with its own registration record, and the reverse entry is Dr 705 1,000 / Dr 477 210 / Cr 473 150 / Cr 430 1,060. The new amount to collect is 5,300 - 1,060 = 4,240, which matches 4,000 + 840 - 600.

Penalties and what an ERP must do in Spain

Article 201 bis of the General Tax Law makes it a serious offence both to produce and sell, and to hold, systems that do not meet Article 29.2.j). For the producer or seller, the fixed fine is EUR 150,000 for each financial year with sales and for each type of system, or EUR 1,000 for each system sold without the required certificate. For a user holding a non-compliant or altered system, the fixed fine is EUR 50,000 per financial year.

An ERP that issues invoices in Spain has to treat an issued invoice as a fact that is never changed, only cancelled or corrected, and should start preparing now the data that B2B e-invoicing will require.

• Consecutive numbering series by location or invoice type
• A registration and cancellation record per invoice, with a chained hash
• The QR code and legend on the invoice layout
• Corrective invoices instead of edits or deletions
• VAT rates, equivalence surcharge and personal income tax withholding per line
• Validated tax IDs (NIF) for customers and suppliers
• Tracking of acceptance and payment of each invoice for future B2B e-invoicing
• An event log and backups if the NO VERI*FACTU mode is chosen

Verifactu and e-invoicing with Skyline Nexus ERP

Skyline Nexus ERP already holds the core invoice data that Verifactu records and future e-invoices are built from. Each business location chooses its own invoice numbering scheme, tax rates and tax groups are set in Settings > Tax Rates, and with auto-post on, a final sale produces the entry for receivables, revenue by category and output VAT, with VAT computed per line exactly as in the tax report. Purchases whose line carries withholding tax post with the withholding split out, and sales returns produce credit notes that reverse revenue, VAT and cost of sales. Every accounting change is kept in the Audit Trail with old and new values, the user and the IP address.

National e-invoicing connectors are being rolled out market by market: tell us you operate in Spain and we will confirm the go-live date for Verifactu and B2B e-invoicing for your business. Until that date is confirmed, the working route is to issue the invoices themselves from an adapted invoicing system, fed through the Connector module's REST API, which exposes sales, returns, contacts, taxes and payments; the deadline that applies to you is 1 January or 1 July 2027, so plan the route well before it.

The team knows real-time tax models: Skyline Nexus ERP runs Saudi Arabia's ZATCA Phase 2 integration in production, with certificate onboarding, compliance checks, invoice clearance and reporting, XML and QR codes, and there an invoice already filed is frozen and can only be corrected by a credit or debit note. The interface is available in English and Arabic, with interface translations including Spanish.