E-Invoicing in Spain 2026 (Verifactu & B2B Mandate)
Short answer: Spain has two separate rules that people mix up. The B2B e-invoicing mandate (from the Ley Crea y Crece) requires structured e-invoices between businesses from 6 October 2027 for companies with turnover above €8 million and from 6 October 2028 for everyone else. Verifactu is a different rule about invoicing software: it applies from 1 January 2027 for companies and 1 July 2027 for the self-employed under current law, though the government announced in October 2026 that it plans to push it to October 2028. Foreign businesses without a Spanish establishment are mostly outside both.
This guide is for small online sellers: a Spanish SL or autónomo selling on Shopify or wholesale, and UK, US or EU businesses with Spanish customers or a Spanish VAT number. For the wider picture, see the EU e-invoicing overview.
Spain e-invoicing at a glance
Section titled “Spain e-invoicing at a glance”| B2B e-invoicing mandate | Verifactu (invoicing software rules) | |
|---|---|---|
| Law | Ley 18/2022 (Crea y Crece), Royal Decree 238/2026, Order HAC/1028/2026 | Royal Decree 1007/2023, dates amended by Royal Decree-law 15/2025 |
| Status | Approved. Countdown started 6 October 2026 | Approved. In a voluntary test period until the deadline |
| Who’s in scope | Businesses and professionals invoicing business customers established in Spain | Businesses established in Spain that issue invoices with software, outside SII and the Basque/Navarra regimes |
| Key dates | Turnover over €8m: 6 October 2027. Everyone else: 6 October 2028 | Corporate taxpayers: 1 January 2027. Self-employed and others: 1 July 2027. Proposed move to October 2028, not yet law |
| Formats | EN 16931 data in UBL, CII, EDIFACT or Facturae | Invoice records with a hash chain and a QR code on each invoice |
| Platform | The tax agency’s free public solution, or private platforms that copy every invoice to it | Your own software. In “VERI*FACTU” mode it sends records to the tax agency as you invoice |
| Covers | B2B only. Not consumer tickets | Every invoice and ticket, B2B and B2C |
| Penalties | Warning or fine of up to €10,000 (Ley 56/2007) | €50,000 per year for users of non-compliant software |
| Non-resident scope | Tied to Spanish invoicing rules and a Spanish-established customer. Most reverse-charge sales by foreign suppliers are outside | Only non-residents with a Spanish permanent establishment |
Other systems you may meet: SII (real-time VAT book reporting for large companies), TicketBAI (the Basque Country’s own invoicing software rule) and FACe (e-invoicing to public bodies).
The B2B e-invoicing mandate (Ley Crea y Crece)
Section titled “The B2B e-invoicing mandate (Ley Crea y Crece)”Is it approved?
Section titled “Is it approved?”Yes. The legal steps are now complete:
- Ley 18/2022 of 28 September 2022 (Ley de creación y crecimiento de empresas) amended Ley 56/2007 so that all businesses and professionals must issue, send and receive e-invoices in their dealings with each other.
- Royal Decree 238/2026 of 25 March 2026, published in the BOE on 31 March 2026 and in force since 20 April 2026, sets out how the system works.
- Order HAC/1028/2026 of 2 October 2026, published on 5 October 2026 and in force since 6 October 2026, regulates the tax agency’s public e-invoicing solution. Its entry into force started the countdown.
The phase-in
Section titled “The phase-in”The tax agency confirmed the dates in a notice of 7 October 2026:
| Who | E-invoicing obligation | Reporting invoice statuses and payments |
|---|---|---|
| Businesses with turnover (volumen de operaciones) over €8 million in the previous year | 6 October 2027 | 6 October 2027 |
| All other companies and legal entities | 6 October 2028 | 6 October 2028 |
| Self-employed individuals (autónomos) and entities taxed as partnerships (atribución de rentas) | 6 October 2028 | 6 October 2029 |
For their first 12 months under the rule, businesses over €8 million must also send a PDF copy with each e-invoice, unless the customer agrees to receive the structured file alone.
How it works
Section titled “How it works”- Public solution or private platform. The tax agency (AEAT) runs a free public e-invoicing solution (Solución Pública de Facturación Electrónica). You can send and receive invoices through it, or through a private platform. It must be available at least two months before the first obligation date.
- Every invoice is copied to the AEAT. If you use a private platform, it must send a faithful copy of each invoice, in UBL, to the public solution when you issue it.
- Private platforms must interconnect. A platform must connect to another platform at a customer’s request, free of charge, within a month. Until then, invoices go through the public solution.
- Formats. Invoices follow the European standard EN 16931 and can be sent as UBL, CII, EDIFACT or Facturae. Peppol is allowed on private platforms.
- Status reporting. The buyer must report when it accepts or rejects an invoice and when it has paid it in full, within four days. This is the point of the law: to track late payment between businesses.
- What’s excluded. Simplified invoices (facturas simplificadas, the tickets you give consumers) are out, except qualified simplified invoices. A few regulated sectors, such as the electricity and gas market operators, are excluded too.
The AEAT will also offer a free form or app for issuing invoices and reporting payments, aimed at small businesses with few invoices.
Penalties
Section titled “Penalties”Ley 56/2007, as amended by Ley 18/2022, provides for a warning or a fine of up to €10,000. Practitioners read it as covering businesses that fail to issue, send or receive B2B e-invoices; the 2026 decree and order don’t restate the penalty, so treat the exact scope as an interpretation. It sits alongside the general invoicing penalties in Spain’s tax code. No fine applies before your phase date.
Verifactu: the invoicing software rules
Section titled “Verifactu: the invoicing software rules”Verifactu (written VERI*FACTU) is not e-invoicing. It doesn’t change how invoices reach your customer. It changes the software you use to create them, so that invoices can’t be deleted or altered after the fact.
What the software must do
Section titled “What the software must do”Under Royal Decree 1007/2023 (the Reglamento de sistemas informáticos de facturación), every invoicing system used by a business in scope must:
- Create a billing record for every invoice or ticket at the moment it’s issued, chained to the previous one with a hash so records can’t be changed silently
- Print a QR code on every invoice, which the customer can scan to check it with the AEAT
- Keep records intact, traceable, readable and accessible to the tax agency
- Come with a statement of compliance (declaración responsable) from the software producer
There are two ways to comply:
| Mode | How it works |
|---|---|
| VERI*FACTU | Your software sends each billing record to the AEAT automatically. Invoices carry the “VERI*FACTU” legend. You don’t need to sign and store the records yourself |
| No VERI*FACTU | Records stay in your system, electronically signed, and you hand them over if the AEAT asks |
Choosing VERI*FACTU mode is voluntary. If you choose it after your deadline, you must stay in that mode at least until the end of that calendar year.
Verifactu dates
Section titled “Verifactu dates”| Who | Original date | Current law (RDL 15/2025) | Announced October 2026 |
|---|---|---|---|
| Software producers | 29 July 2025 | 29 July 2025 (already applies) | No change |
| Companies paying corporate income tax (SL, SA and other Impuesto sobre Sociedades payers) | 1 July 2025 | 1 January 2027 | October 2028 (proposed) |
| Self-employed (IRPF), partnerships (atribución de rentas), non-residents with a Spanish permanent establishment | 1 July 2025 | 1 July 2027 | October 2028 (proposed) |
Verifactu has already been postponed twice: by Royal Decree 254/2025 (to 2026) and by Royal Decree-law 15/2025 of 2 December 2025 (to 2027).
The proposed move to 2028 is not law yet. On 5 October 2026 the Ministry of Finance published a note saying it plans to postpone the remaining Verifactu obligations until October 2028, to line them up with the B2B e-invoicing date for smaller businesses, and to review parts of the regulation in light of the EU’s ViDA reforms. As of late October 2026, the AEAT’s own pages still show 1 January and 1 July 2027 as the binding dates. Until the change is published in the BOE, plan for 2027.
Who’s in scope: the “four NOs”
Section titled “Who’s in scope: the “four NOs””The AEAT’s scope FAQ sums it up as four conditions. You’re in scope if you’re a business or professional established in Spain and you:
- Do NOT invoice purely by hand. Using any invoicing software, a till or an online invoicing tool brings you in. Word or Excel alone generally counts as manual.
- Are NOT in SII, compulsorily or voluntarily.
- Do NOT have your tax address in the Basque Country or Navarra, which run their own systems.
- Do NOT have an exemption decision from the AEAT.
Penalties
Section titled “Penalties”| Who | Fine |
|---|---|
| Businesses using non-compliant, uncertified or altered invoicing software | €50,000 per tax year |
| Software producers and sellers | €150,000 per year for each type of non-compliant system, plus €1,000 per system sold without the compliance statement |
For small Spanish businesses: what to do
Section titled “For small Spanish businesses: what to do”The 90% case is a small Spanish SL or autónomo that uses invoicing software and isn’t in SII.
- Verifactu first. Ask your invoicing, POS or e-commerce app whether it is Verifactu-ready, and when. Shopify apps, POS tills and accounting tools all count as invoicing software if they issue your invoices or tickets.
- Plan for 1 January 2027 (companies) or 1 July 2027 (autónomos), and treat October 2028 as a possible reprieve, not a certainty.
- B2B e-invoicing next. If you sell to Spanish businesses and your turnover is under €8 million, your date is 6 October 2028. Decide whether you’ll use the AEAT’s free public solution or a private platform.
- Consumer sales. Tickets to consumers are outside the B2B mandate but inside Verifactu.
Worked example: a ceramics studio in Valencia
Section titled “Worked example: a ceramics studio in Valencia”Cerámica Azahar SL has turnover of €1.2 million. It sells to consumers on Shopify and wholesales to Spanish shops. It isn’t in SII.
Verifactu, from 1 January 2027 (current law): every Shopify order and wholesale invoice must be produced by software that keeps chained records and prints a QR code. If its invoicing app isn’t compliant by then, the exposure is a €50,000 fine per year.
B2B e-invoicing, from 6 October 2028: a Madrid shop orders €3,000.00 of tableware.
- Net amount: €3,000.00
- IVA at 21%: €630.00
- Total: €3,630.00
Cerámica Azahar issues the invoice through the public solution or its platform in a structured format. The shop must report acceptance and, once it has paid, the full payment date, each within four days.
Shopify orders: a consumer buys a vase for €60.50 including 21% IVA (€50.00 plus €10.50 VAT). The simplified ticket is outside the B2B mandate, but it must carry a Verifactu QR code.
A distributor in the same city with €12 million turnover would have to e-invoice from 6 October 2027. If it’s in SII because its turnover is over €6 million, Verifactu doesn’t apply to it.
SII for larger businesses
Section titled “SII for larger businesses”The Immediate Supply of Information (Suministro Inmediato de Información, SII) has been in place since 2017. Businesses in it send their VAT invoice books to the AEAT electronically within four working days of issuing or recording an invoice.
SII is mandatory for:
- Businesses with turnover above €6,010,121.04 in the previous year
- Businesses registered for monthly VAT refunds (REDEME)
- VAT groups
Any business can join voluntarily. SII and Verifactu are mutually exclusive: if you’re in SII, Verifactu doesn’t apply. SII doesn’t exempt you from the B2B e-invoicing mandate.
The Basque Country and Navarra
Section titled “The Basque Country and Navarra”The Basque Country and Navarra have their own tax administrations (haciendas forales), so Verifactu doesn’t apply to businesses with their tax address there.
- Basque Country: TicketBAI. Álava, Bizkaia and Gipuzkoa already require TicketBAI, their own invoicing software rule. Each invoice gets a signed file and a QR code, and is sent to the provincial tax office. In Bizkaia it forms part of the wider Batuz system.
- Navarra. Navarra is developing its own system, often called NaTicket. As of October 2026, no decree setting dates or technical rules had been published.
The B2B e-invoicing mandate applies across Spain, including in the Basque Country and Navarra, under agreements between the provincial and state tax agencies.
Invoicing public bodies: FACe
Section titled “Invoicing public bodies: FACe”Invoices to Spanish public administrations have been electronic since 15 January 2015 under Ley 25/2013. They go through FACe, the general entry point for public-sector invoices, in the Facturae XML format, signed electronically. Some administrations exempt invoices of up to €5,000, so check with the body you invoice. The B2B mandate replaces the separate FACeB2B system that public-contract subcontractors used.
Foreign sellers: UK, US and non-established businesses
Section titled “Foreign sellers: UK, US and non-established businesses”Spain’s rules are built around businesses established in Spain. A Spanish VAT number on its own doesn’t bring you into Verifactu, and usually not into the B2B mandate either.
| Your situation | Verifactu | B2B e-invoicing mandate |
|---|---|---|
| No Spanish VAT number, selling to Spanish consumers through OSS or IOSS | No | No (consumer sales are outside the mandate anyway) |
| Spanish VAT number, no Spanish establishment, stock in a Spanish 3PL, selling to consumers | No | No (consumer tickets are excluded) |
| Selling goods or services to a Spanish business, which accounts for the VAT under the reverse charge | No | Generally no (see below) |
| Spanish permanent establishment or branch | Yes | Yes, on the same dates as Spanish businesses |
| A Spanish subsidiary (SL) | Yes | Yes |
Why reverse-charge sales are generally outside the mandate. Royal Decree 238/2026 applies to invoices that Spanish invoicing rules (Royal Decree 1619/2012) require, sent to customers established in Spain. When a non-established supplier sells to a Spanish business and the customer accounts for the VAT, Spain’s invoicing rules generally don’t govern that invoice: the supplier’s home-country rules do. That’s our reading of how the two decrees fit together. The decree doesn’t address foreign suppliers in so many words, so confirm it for your case if you invoice Spanish businesses in volume.
What your Spanish customers will do. From 2027 and 2028, Spanish businesses will receive most invoices through the public solution or a platform. Some may ask whether you can send a structured invoice. You can choose to, but foreign suppliers aren’t obliged to. Expect them to ask for your VAT number and, for services, to self-account for 21% IVA.
Worked example: a US SaaS selling to Spain
Section titled “Worked example: a US SaaS selling to Spain”A US software company sells subscriptions to Spanish consumers and businesses.
- Consumers: it charges 21% IVA and declares it through non-Union OSS. A €20.00 monthly plan becomes €24.20. No Verifactu, no e-invoicing.
- Businesses: it invoices a Barcelona agency €500.00 a month with no Spanish VAT. The agency self-accounts for €105.00 of IVA under the reverse charge. The invoice can be a normal PDF.
If the company later opened a Madrid office that counted as a permanent establishment, both Verifactu and the B2B mandate would apply to that establishment’s invoicing.
How GoodVat helps
Section titled “How GoodVat helps”GoodVat Global Tax Compliance covers both the invoicing and the VAT side:
- Work out what applies to you in Spain: OSS, Spanish registration, Verifactu, the B2B mandate and the dates for your size
- Issue your invoices with GoodVat E-invoicing, with invoicing records kept to Verifactu’s rules and SII reporting for businesses that file it
- Register you for Spanish VAT, OSS or IOSS where you need it
- Calculate the right IVA rate for each product at checkout
- File your returns from the same invoice records
Checklist
Section titled “Checklist”- Are you established in Spain? If not, and you have no Spanish permanent establishment, Verifactu doesn’t apply and the B2B mandate generally won’t.
- Spanish businesses: are you in SII? If yes, skip Verifactu. If not, get a Verifactu-ready invoicing system for 1 January 2027 (companies) or 1 July 2027 (autónomos).
- Check your turnover for the B2B date: over €8 million means 6 October 2027, otherwise 6 October 2028.
- Choose your channel for B2B e-invoices: the AEAT’s free public solution or a private platform.
- Prepare to report payments. Your accounts team will need to confirm acceptance and payment of supplier invoices within four days.
- Basque Country: you’re on TicketBAI, not Verifactu. Navarra: watch for the foral decree.
- Public sector customers: keep using FACe and Facturae.
- Watch the BOE for the formal Verifactu postponement before relying on October 2028.
When is e-invoicing mandatory in Spain?
Section titled “When is e-invoicing mandatory in Spain?”B2B e-invoicing becomes mandatory on 6 October 2027 for businesses with turnover above €8 million and on 6 October 2028 for all other businesses and the self-employed. The dates come from Royal Decree 238/2026 and the ministerial order that took effect on 6 October 2026. Invoices to public bodies have been electronic through FACe since 2015.
Is Verifactu the same as e-invoicing?
Section titled “Is Verifactu the same as e-invoicing?”No. Verifactu is a rule about the software you invoice with: it must keep tamper-proof records of every invoice and can send them to the tax agency. The B2B e-invoicing mandate is about sending structured invoices to business customers. They have different laws, dates and scopes, and many businesses will be subject to both.
When does Verifactu start?
Section titled “When does Verifactu start?”Under current law, companies paying corporate income tax must use compliant invoicing software from 1 January 2027, and the self-employed and other taxpayers from 1 July 2027. On 5 October 2026 the Ministry of Finance announced it plans to move these obligations to October 2028. That change still has to be approved, so plan for the 2027 dates.
Do the self-employed (autónomos) need Verifactu?
Section titled “Do the self-employed (autónomos) need Verifactu?”Yes, if they issue invoices with software and aren’t in SII or registered in the Basque Country or Navarra. Under current law their deadline is 1 July 2027. Someone who writes every invoice by hand, with no invoicing software at all, is outside Verifactu.
Do foreign companies need Verifactu or Spanish e-invoicing?
Section titled “Do foreign companies need Verifactu or Spanish e-invoicing?”Verifactu applies only to businesses established in Spain, including non-residents with a Spanish permanent establishment. A foreign company with only a Spanish VAT number is outside it. The B2B mandate covers invoices that Spanish invoicing rules require, to business customers established in Spain, and most reverse-charge sales by non-established suppliers fall outside those rules.
What is the penalty for not using Verifactu-compliant software?
Section titled “What is the penalty for not using Verifactu-compliant software?”A business that uses invoicing software that doesn’t meet the rules faces a fine of €50,000 for each tax year. Software producers and sellers face €150,000 per year for each type of non-compliant system. These fines only apply once the obligation date has passed.
Does the Spanish B2B mandate apply to sales to consumers?
Section titled “Does the Spanish B2B mandate apply to sales to consumers?”No. The mandate covers invoices between businesses and professionals. Simplified invoices (tickets) are excluded unless they are qualified simplified invoices. Verifactu, by contrast, covers every invoice and ticket your software issues, including to consumers.
Related guides
Section titled “Related guides”- E-invoicing in the EU: every country’s mandate and timeline in one place
- E-invoicing in France: the September 2026 and 2027 reform, and e-reporting
- E-invoicing in Italy: SdI and FatturaPA, mandatory since 2019
- E-invoicing in Germany: the B2B mandate that started with receiving in 2025
- E-invoicing in Belgium: Peppol B2B e-invoicing since January 2026
- E-invoicing in the Netherlands: where the Dutch plans stand
- Selling to Spain: VAT rates and rules: IVA rates, registration and the Canary Islands
- UK sellers: selling to Spanish customers: customs, Correos fees and IVA after Brexit
- Non-Union OSS for digital services: how non-EU SaaS businesses charge EU VAT