Electronic invoicing in Spain: Facturae, SII and the new VeriFactu framework

Spain is rapidly expanding electronic invoicing. After focusing mainly on public sector transactions and the SII system for large companies, it now moves into a new stage with the VeriFactu regulation, mandatory for all businesses by 2027. Technical changes, new legal obligations, and an overhaul of invoicing processes are rapidly reshaping Spain’s regulatory landscape.

While the reform represents a major national shift, it does not fully unify the Spanish landscape: companies already subject to the SII regime will remain within it, and the Basque Country maintains its own mandatory system (TicketBAI). The new VeriFactu framework therefore complements existing regimes rather than replacing them.

Electronic invoicing in Spain: what is the current situation?

On 2 December 2025, the Spanish government officially postponed the implementation of Verifactu. The mandatory compliance date has been moved from 2026 to 2027. Implementation will begin on 1 January 2027 for companies, and on 1 July 2027 for SMEs and the self-employed. This postponement was approved by the Council of Ministers via a decree-law from the Ministry of Finance.

The schedule to remember is therefore:

• 1 January 2027: companies subject to corporation tax.
• 1 July 2027: other companies and self-employed workers.

The SII continues to operate independently.

A well-established Spanish system

Spain already has an advanced electronic invoicing ecosystem. Three areas currently structure the system:

1. Electronic invoicing to the public sector, which has been mandatory for several years.
2. The SII, a system for the near-immediate transmission of invoicing records for large companies.
3. The new national VeriFactu framework, which will impose strict technical requirements on all invoicing software from 2027 onwards.

Essential terms for understanding the Spanish system

• Facturae: Official XML format for invoices addressed to the public sector (versions 3.2.1 and 3.2.2).
• FACe / FACeB2B: Platforms for submitting electronic invoices to public administrations.
• SII (Suministro Inmediato de Información): Near-immediate reporting of invoicing records to the AEAT.
• SIF (Sistemas Informáticos de Facturación): Software compliant with the VeriFactu regulation.
• VeriFactu system (Verifiable invoice issuance systems): Regulation requiring integrity, traceability, audit trail, QR codes, and, in some cases, automatic transmission of invoices.
• QR VeriFactu: Mandatory QR code for all invoices issued by a SIF.
• TicketBAI: Mandatory regional system in the Basque Country.

The three pillars of the Spanish system

1. Facturae: the official B2G format

Invoices intended for the public sector must be sent in Facturae XML format via the FACe or FACeB2B platforms.

2. The Suministro Inmediato de Información (SII) system: immediate transmission of VAT records

Certain companies — large groups registered under certain tax regimes — must transmit their invoicing records to the Agencia Estatal de Administración Tributaria (AEAT) in near real time.

3. VeriFactu: the big change from 2027

The new framework, known as Reglamento VeriFactu, will require all invoicing systems to guarantee several key elements from 2027. These include:

• data integrity,
• traceability and a complete audit log,
• the immutability of invoicing series,
• a mandatory QR code,
• the transmission of data when the company activates this mode.

This is a structural reform comparable to the systems already in place in Portugal and Italy.

It is important to note that activating the VeriFactu transmission mode (automatic, real-time submission of invoices to the AEAT) remains optional. Companies may comply with VeriFactu by implementing integrity, logging and QR-code requirements without enabling automatic transmission. The AEAT encourages this mode, but it is not mandatory by default.

Overview of the Spanish system

Who is affected, and how?

• Suppliers to public administrations: already subject to the Facturae format.
• Large companies already using SII: obligations remain unchanged, with a few adjustments.
• All Spanish companies from 2027: obligation to use a VeriFactu-compliant SII.

SII vs. VeriFactu: Do not confuse

Key technical requirements

SIFs must guarantee:

• The integrity and immutability of data.
• An event log (creations, cancellations, corrections, hashes, etc.).
• The time-stamping and irreversibility of series.
• The QR VeriFactu code on each invoice.
• Compliant legal storage.
• A Responsible Declaration filed by the publisher.

In terms of formats and signatures, Facturae is recognised as the standard in B2G transactions. The use of electronic signatures (XAdES or equivalent) is typically required in most cases.

Points still subject to clarification

Although the core framework is defined, several technical and enforcement details remain subject to final determination by the AEAT. These include:

• the exact granularity of the technical event log,
• certain aspects of the QR VeriFactu structure,
• the operational procedures for inspections and incident reporting,
• the interaction between VeriFactu and regional systems such as TicketBAI.
  Updates are expected through AEAT guidelines, FAQs and technical manuals.

What you should not forget

• Heavy penalties for non-compliance.
• Possible interaction between national framework and regional systems (TicketBAI).

The Basque Country (Álava, Gipuzkoa and Bizkaia) enforces its own mandatory system, TicketBAI, which continues to apply independently of VeriFactu. Companies operating in these territories may therefore be subject to both frameworks simultaneously, with partially overlapping but distinct technical requirements.

• Need for robust legal archiving (WORM – Write Once Read Many, indexing).
• Check EN-16931 compatibility and Peppol networks for international use.

Practical checklist for your teams

• Determine whether you are subject to SII or corporation tax.
• Map current flows (format, signature, ERP).
• Obtain a compliance commitment from your SII publisher.
• Test Facturae, FACe, archiving and ERP integration.
• Set up secure legal archiving.

FAQ – Frequently asked questions

• Does VeriFactu replace the SII?
  No, the two coexist.
• Will I have to send all my invoices in real time?
  Only if the company activates VeriFactu mode; otherwise, only the logging requirements apply.
• Is Facturae becoming mandatory for B2B?
  No, only for B2G.
• Is the classic PDF still allowed?
  Yes, if it is generated by a compliant SIF and bears the QR code.
• Is TicketBAI being phased out?
  No, it is still mandatory in the Basque Country.
• Will Peppol be required?
  Not mandatory, but recommended for EU interoperability.

Conclusion

By the 4th quarter of 2025, Spain will already be well-established in terms of electronic invoicing. With the arrival of VeriFactu in 2027, all companies must prepare to upgrade their invoicing systems. Anticipating these changes is essential to avoid risks, additional costs, and penalties.

Official sources / External documents

• AEAT website — VeriFactu Regulation (computerised invoicing systems): FAQ, features, scope of application.
• AEAT – ‘Computerised invoicing systems (VeriFactu)’ – Manual / New features for 2025.
• For a detailed analysis of SIF obligations, QR codes, technical journals and ERP impacts, please see our article on the VeriFactu regulation.