Mandatory E-Invoicing in Spain: Deadlines, Technical Requirements, and How to Adapt

Few tax obligations have generated as much confusion as e-invoicing in Spain, and with good reason: under that label live two separate rules, with separate calendars and separate requirements, that most articles cheerfully mix together. The first is Verifactu, the anti-fraud regulation that governs how your invoicing software must work. The second is B2B e-invoicing under the Crea y Crece Law, which governs the format in which you’ll have to issue and receive invoices with other companies and self-employed workers. You can comply with one and breach the other, and the penalties for each run down separate tracks.

The picture, moreover, has shifted: the Government extended the Verifactu deadlines through Royal Decree-Law 15/2025, moving the obligation to January 1, 2027 for companies and July 1, 2027 for self-employed workers, and finally approved the B2B e-invoicing regulation (Royal Decree 238/2026), whose 12 and 24-month countdown will start when the Ministerial Order that activates the public solution is published. This guide sorts out the whole board: what each rule requires, who it affects, what deadlines really apply, what technical requirements your software must meet, and what fines are at stake.

What Is Mandatory E-Invoicing in Spain?

To understand the system, you have to separate the two layers from minute one:

• Verifactu (computerized invoicing systems): it doesn’t require you to send electronic invoices to your clients; it requires the program you generate invoices with to meet requirements of integrity, unalterability, and traceability: each invoice generates a record with a digital fingerprint chained to the previous one, the software keeps an event log, and the invoice incorporates a QR code. You can keep handing your client a paper or PDF invoice: what changes is what happens underneath.
• B2B e-invoicing (Crea y Crece Law): this one does change the exchange. All invoices between business owners and professionals established in Spain will have to be issued and received in structured electronic format (machine-readable, not a simple PDF), through certified private platforms or the free public solution, with reporting of the invoice statuses (acceptance, rejection, and payment) to combat late payment.

The third piece of the puzzle has been working for years: e-invoicing with the Public Administrations (B2G) has been mandatory since 2015 through FACe in Facturae format. If you invoice the public sector, you already know that part.

Regulatory Framework: Crea y Crece Law and Verifactu

The regulatory tree of each regime, because knowing the source avoids confusion:

• Verifactu comes from the Anti-Fraud Law (Law 11/2021) and is developed in Royal Decree 1007/2023, amended by RD 254/2025, with the technical specifications in Order HAC/1177/2024. Royal Decree-Law 15/2025, of December 2, extended the deadlines for those subject to it by a year, leaving the calendar in force in 2027.
• B2B e-invoicing comes from Article 12 of Law 18/2022, Crea y Crece, and its regulation is Royal Decree 238/2026, of March 25, in force since April 20, 2026. Its effective application is deferred until the publication of the Ministerial Order developing the public invoicing solution, still pending.

A nuance that explains many extensions: both systems require massive technological infrastructure (adapted software, interoperable platforms, Tax Agency services), and the legislator has preferred to delay rather than launch a half-built system. Software developers, though, are already bound: their programs had to be adapted to Verifactu since July 29, 2025.

Who Does It Affect and From When?

Verifactu affects companies and self-employed workers with activity in common territory who use computerized invoicing systems, with two important exclusions:

• Those covered by the SII (Immediate Supply of Information: large companies, VAT groups, and voluntary members) are left out of Verifactu, because they already send their records to the Tax Agency almost in real time. The same logic by which the SII exempts from other informative returns, as we explain in our guide on who should file form 347.
• The provincial territories (Basque Country and Navarre) have their own anti-fraud systems, TicketBAI and Batuz, functional equivalents of Verifactu.

B2B e-invoicing, for its part, will reach all business owners and professionals established in Spain in their operations with each other, with no distinction of size or sector, when each one reaches their date. Invoices to individuals (B2C) and, in general, operations with companies not established in Spain are left out. For the self-employed worker, both obligations add to the rest of their tax calendar, which is worth keeping in order: we review it in our guide on the tax obligations of the self-employed worker in Spain.

Deadlines by Company Size and Turnover

Three practical readings of the table. First: even if your Verifactu date is 2027, the adapted software already exists and is required of your provider; the current period is the ideal window for voluntary adaptation and testing, not a grace period to forget about the topic. Second: the B2B invoicing clock hasn’t started running, but when the Ministerial Order is published, large companies will have only a year and the rest two, and implementation projects in mid-sized organizations consume months. Third: if you set up a company now, the smart move is to be born already adapted and not buy software twice, a decision that’s part of the orderly launch we describe in our guide on how to create a company in Spain.

Technical Requirements: Formats and Approved Systems

What Verifactu Requires of Your Software

• Integrity and unalterability: each invoice generates an invoicing record with a fingerprint (hash) chained to the previous record, so that deleting or modifying an invoice leaves a trace. Gone are the parallel accounts and the dual-use software.
• Traceability and event log: the system records the relevant events (startups, cancellations, incidents) and keeps them.
• QR code on all invoices, which lets the client (and the Inspectorate) verify the invoice with the Tax Agency.
• Two modalities to choose from: the VERI*FACTU modality, in which the software sends the records to the AEAT continuously and the invoices display the verifiable-invoice legend, and the non-sending modality, equally legal, with reinforced requirements of electronic signature and retention. The first simplifies obligations and lowers the risk profile in checks; the second preserves the privacy of the invoicing flow.

What B2B E-Invoicing Will Require

• Accepted structured formats: Facturae, UBL, CII, and EDIFACT. A PDF by email is not an electronic invoice for these purposes.
• Dual exchange route: certified private platforms interoperable with each other, and the public e-invoicing solution managed by the Tax Agency, free and designed for small businesses and the self-employed, which will also receive a copy of the invoices sent through private platforms.
• Invoice statuses: the recipient will have to report the acceptance or rejection and the effective payment within set deadlines of a few days, with additional adaptation margin for the smallest. It’s the piece designed to expose the real late payment between companies.

Software and E-Invoicing Solutions Available

The operational question we get every week: what do I do about my invoicing? The criterion, by profile:

• If you already use commercial invoicing software: require from your provider the responsible declaration that the system complies with RD 1007/2023 (it’s the document that certifies the adaptation) and ask about their roadmap for the B2B formats. The large manufacturers are preparing dual compliance in the same product.
• If you invoice with Excel, Word, or manual templates: that scheme can’t meet the integrity and record-chaining requirements. You have until your 2027 date to migrate, but migrating means learning a new program: the sooner, the less pain.
• If you issue few invoices: the AEAT’s own free invoicing app covers Verifactu at no cost, and the public solution will cover the B2B exchange. For a self-employed service provider with a handful of clients, the public combination can be enough.
• If you work with a tax advisory firm: coordinate the choice of software with them, because the integration between your invoicing and their accounting is where time is won or lost every quarter. The technological adaptation and formal compliance of companies is exactly the terrain of our corporate income tax and tax compliance in Spain service.

For newly created companies and startups, the advice is by design: choosing from day one a tool that covers Verifactu and the B2B structured formats avoids a second migration in the middle of the growth phase, and fits into the package of initial legal and operational decisions we work on in our legal advice for startups in Spain service.

Penalties for Non-Compliance with E-Invoicing

The two regimes penalize down separate tracks, and the figures aren’t symbolic:

• Verifactu (Article 201 bis of the General Tax Law): manufacturing or marketing software that doesn’t comply with the regulation is penalized with up to 150,000 € per year and system; the mere possession or use of non-certified software by the company or the self-employed worker, with 50,000 € per year. The user’s penalty doesn’t require any fraud to be proven: the non-compliant software is enough.
• B2B e-invoicing (Crea y Crece Law): failing to issue or give access to electronic invoices when required is penalized with fines of up to 10,000 €.
• The indirect risk: beyond the fines, an irregular invoicing system is an invitation to a tax check: the chained records and the QR are precisely the tools with which the Inspectorate will cross-reference data on a massive scale.

Mandatory e-invoicing is, at bottom, a change of era in the relationship between companies and the Tax Agency: from declaring what you invoiced to invoicing under systems that declare on their own. The sensible path doesn’t depend on your size but on order: confirm which regime applies to you and on what date, require documented compliance from your software provider, take advantage of the current window to migrate without urgency, and settle the dual adaptation (Verifactu and B2B formats) in a single move.

At ILLAY Legal we help companies, the self-employed, and startups comply with the whole tax and invoicing cycle through fully online service: analysis of your obligations, coordination of the technological adaptation with your software or advisory firm, and ongoing compliance before the Tax Agency. Tell us how you invoice today and we’ll tell you exactly what you’re missing and in what order to resolve it.

Frequently Asked Questions About Mandatory E-Invoicing in Spain