< Blog
Electronic invoicing in Spain: Facturae, SII and the new VeriFactu framework (2027–2028)
Electronic invoicing is undergoing a major acceleration in Spain. Until now, it has focused primarily on transactions with the public sector and on the SII system for businesses subject to this requirement. It is now entering a new phase with the regulation governing invoicing computer systems (RRSIF), commonly associated with VeriFactu, which introduces new technical requirements for invoicing software. Initially scheduled for 2026 and subsequently postponed to 2027, its implementation is once again the subject of a postponement announcement in October 2026. At the same time, the reform introducing mandatory electronic invoicing between businesses and professionals (B2B) reached an important regulatory milestone in 2026. Amid technical changes, new legal obligations and a restructuring of invoicing systems, Spain’s regulatory landscape is evolving rapidly.
Although these reforms represent major changes, they do not fully standardise Spain’s invoicing landscape: businesses subject to SII are excluded from the scope of RRSIF for their own invoices, while the Basque Country and Navarre have their own tax frameworks. B2B electronic invoicing, meanwhile, is a separate system governing invoice exchanges between businesses and professionals. The new framework therefore complements the existing ecosystem without replacing the regimes already in place.
Article updated on 12 October 2026. The October 2028 deadlines announced in connection with RRSIF are presented as a postponement under consideration by the Spanish Ministry of Finance, pending formal legal adoption. By contrast, the B2B electronic invoicing framework is covered by regulatory texts published in 2026, with separate general deadlines in October 2027 and October 2028.
On 2 December 2025, the Spanish Government officially announced the postponement of the entry into force of the regulation governing invoicing computer systems, which had initially been scheduled for 2026. The timetable established at that point required compliance by 1 January 2027 at the latest for businesses subject to Corporation Tax, and by 1 July 2027 for other taxpayers within scope.
However, on 5 October 2026, the Spanish Ministry of Finance announced its intention to postpone the remaining obligations until October 2028, in order to bring the RRSIF timetable more closely into line with that for mandatory B2B electronic invoicing.
As at the date of this update, this announcement represents a proposed change: the published regulatory deadlines remain those set for 2027 until the postponement has been formally enacted.
The RRSIF timetable to bear in mind is therefore as follows:
SII continues to operate independently. Businesses falling within its scope are excluded from RRSIF for their own invoices.
At the same time, B2B electronic invoicing now has its own regulatory framework. Royal Decree 238/2026 of 25 March 2026 develops the system for electronic invoice exchange between businesses and professionals. Order HAC/1028/2026, published on 5 October 2026 and entering into force on 6 October 2026, sets out how the public electronic invoicing solution operates.
The general deadlines for the B2B reform are as follows:
Volumen de operaciones is a Spanish tax-law concept and should not automatically be equated with accounting turnover. The precise scope of application and transitional provisions should be checked against the applicable legislation.
These dates relate to the B2B reform and do not confirm the proposed postponement of RRSIF.
Spain already has a well-developed electronic invoicing ecosystem. Three main strands underpin the existing framework.
First, electronic invoicing for the public sector, which has been mandatory for the relevant transactions for several years.
Second, SII, the system for the near-real-time submission of VAT records by businesses and other taxpayers subject to this requirement.
Finally, the national framework governing invoicing computer systems (RRSIF), associated with VeriFactu, which imposes technical requirements concerning the integrity, traceability and retention of invoicing records on software falling within its scope.
The regulatory framework for B2B electronic invoicing has now been added to these arrangements. Royal Decree 238/2026 and Order HAC/1028/2026 define, among other things, the role of private platforms, the role of the public solution managed by the AEAT, and the rules governing invoice transmission and interoperability.
The B2B reform does not replace either SII or RRSIF. It serves a different purpose: to organise the issuing, transmission, receipt and tracking of electronic invoices between businesses and professionals. Any additional technical specifications should be checked against the AEAT’s official documentation.
Invoices addressed to the public sector must be submitted in Facturae XML format in the cases prescribed by law, including via the FACe platform. FACeB2B addresses certain electronic invoice transmission requirements between businesses.
However, Facturae should not be confused with the general B2B electronic invoicing framework. The applicable formats and platforms depend on the obligation concerned. The fact that software can already generate Facturae invoices does not, in itself, guarantee compliance with all the requirements of the B2B reform.
Certain businesses, particularly large businesses, those registered under the monthly VAT refund regime and those falling within other situations specified by law, must submit their VAT records to the Spanish Tax Agency (Agencia Estatal de Administración Tributaria, or AEAT).
This submission takes place within short time limits, generally four days for the transactions concerned, subject to the applicable rules and exceptions.
SII concerns VAT records rather than the general obligation to produce structured electronic invoices for B2B transactions.
The regulatory framework established by Royal Decree 1007/2023, amended in particular by Royal Decree 254/2025 and Royal Decree-Law 15/2025, requires invoicing systems within scope to ensure:
The regulation provides for two operating modes: VERIFACTU and NO VERIFACTU.
In VERIFACTU mode, invoicing records are transmitted to the AEAT immediately after they are generated. In NO VERIFACTU mode, records are not transmitted systematically, but the software must meet additional requirements, particularly regarding signatures and the event log.
It is important to distinguish between the two modes. Automatic transmission of records to the AEAT is not mandatory for every user subject to RRSIF: a choice between VERIFACTU and NO VERIFACTU is possible, provided all the requirements of the selected mode are met. The QR code remains mandatory in both modes for the invoices concerned. Businesses subject to SII are, for their part, excluded from RRSIF for their own invoices.
B2B electronic invoicing is a separate system. Software that complies with RRSIF/VeriFactu does not automatically meet B2B requirements relating to structured formats, exchange platforms, interoperability or the transmission of a faithful copy to the public solution.
The Spanish framework can be summarised in four complementary components:
These components have different purposes and timetables. Compliance must therefore be assessed separately for each system.
For the B2B reform, using a private platform does not remove all obligations towards the public solution. Businesses issuing invoices without using the public solution must, in particular, transmit a faithful electronic copy of each invoice to it simultaneously, in UBL syntax, under the conditions set out in the legislation.
| Feature | SII | RRSIF / VeriFactu |
|---|---|---|
| Nature | VAT record submission system | Regulation governing invoicing computer systems |
| Who it applies to | Businesses and other taxpayers subject to SII | Businesses and professionals falling within the scope of RRSIF |
| Purpose | Submission of VAT records to the AEAT | Integrity, traceability, retention and security of invoicing records |
| Data concerned | VAT records | Records generated by invoicing software |
| Automatic transmission | Yes, in accordance with SII obligations | In VERIFACTU mode; no systematic transmission in NO VERIFACTU mode |
| QR code | No specific obligation arising from SII itself | Required on invoices covered by RRSIF |
| Interaction | Separate regime | Taxpayers subject to SII are excluded from RRSIF for their own invoices |
B2B electronic invoicing must also be distinguished from both systems. It concerns the exchange of invoices between businesses and professionals, whereas SII deals with VAT records and RRSIF governs invoicing computer systems.
For businesses already subject to SII, VAT record submission obligations remain in force. They are not required to apply RRSIF to their own invoices solely by virtue of that regulation. However, the position of each entity should be checked, particularly where a group has several establishments, operates in different tax territories or uses specific arrangements.
Exclusion from RRSIF should not be interpreted as a blanket exemption from all B2B electronic invoicing obligations: the latter are governed by their own regulatory framework and must be assessed separately.
SIFs falling within the scope of RRSIF must:
As regards formats and signatures, Facturae remains a reference format for electronic invoices addressed to the public sector. Signature requirements nevertheless depend on the format, the system and the transaction flow concerned. Under RRSIF, the signing of records and other technical safeguards must be distinguished from the requirements specific to B2G electronic invoicing.
For B2B electronic invoicing, businesses must also check that their solutions can generate and process structured invoices in the permitted formats, ensure interoperability with the chosen platforms and comply with the system’s transmission requirements.
Royal Decree 238/2026 provides for the use of structured syntaxes, including CII, UBL, EDIFACT and Facturae, within the framework defined by the legislation. Order HAC/1028/2026 specifies that invoices issued through or interconnected with the public solution must comply with the EN 16931 semantic model using UBL syntax.
Businesses using a private platform should therefore check, in particular, that it can support:
The precise versions of the syntaxes, technical profiles and interconnection arrangements should be checked against the AEAT’s official specifications. A particular version of UBL or a specific technical protocol should not be assumed to be mandatory without supporting documentation.
Although the general frameworks have been established, businesses and software providers should monitor several developments, including:
The B2B regulatory framework is no longer entirely forthcoming: Royal Decree 238/2026 and Order HAC/1028/2026 were published in 2026. Businesses should now work from these texts and monitor the AEAT’s supplementary technical documentation.
Updates may be published through legislation, FAQs and AEAT technical manuals.
The Basque Country (Álava, Gipuzkoa and Bizkaia) applies its own tax systems, including TicketBAI. Businesses governed by the foral regulations are not subject to national RRSIF under the conditions set out in the relevant legislation. For groups operating in both common-tax territory and foral territory, obligations must be assessed entity by entity and according to the applicable tax regime.
To ensure compliance, follow these steps:
Here are the key questions you should pay particular attention to.
No. The two systems have different purposes. However, businesses subject to SII are excluded from the scope of RRSIF for their own invoices. B2B electronic invoicing falls under yet another framework and must be assessed separately.
Not necessarily. VERIFACTU mode provides for the automatic transmission of invoicing records to the AEAT. NO VERIFACTU mode does not require systematic transmission, but it imposes additional technical requirements. Businesses subject to SII fall under a separate system.
The rules for transmitting B2B invoices are also distinct. In particular, businesses issuing invoices without using the public solution must transmit a faithful electronic copy in UBL to that solution under the conditions set out in the legislation.
The published regulatory deadlines provide for 1 January 2027 for businesses subject to Corporation Tax and 1 July 2027 for other taxpayers within scope. On 5 October 2026, the Ministry of Finance announced a proposed postponement until October 2028. The final legislation should be checked before this revised timetable is treated as confirmed.
Facturae has historically been associated with electronic invoices addressed to the public sector, but it is also among the syntaxes referred to in the B2B regulatory framework. Using it does not, however, mean that all B2B obligations are automatically satisfied: the semantic model, exchange channel, interoperability rules and transmission obligations must also be met.
No. B2B electronic invoicing governs invoice exchanges between businesses and professionals, whereas RRSIF/VeriFactu governs invoicing computer systems and the traceability of records. A business may be subject to both regimes, depending on its status and any applicable exclusions.
The general deadlines established by the framework published in 2026 are 6 October 2027 for businesses whose volumen de operaciones exceeds €8 million, and 6 October 2028 for other businesses and professionals within scope.
Volumen de operaciones is a Spanish tax-law concept. It should not automatically be equated with accounting turnover. The precise scope of application must be checked against the legislation.
No. The system allows businesses to use private platforms, the public solution or a combination of both. However, businesses issuing invoices without using the public solution must simultaneously transmit a faithful electronic copy of each invoice in UBL to it, under the conditions set out in the legislation.
PDF may continue to be used as a readable representation of an invoice where the applicable rules allow it. However, compliance with RRSIF requirements, including record generation and the tax QR code, must be ensured whenever the invoicing system falls within its scope.
For B2B electronic invoicing, a PDF alone should not be regarded as sufficient where the system requires a structured invoice compliant with the applicable rules. The format and transmission channel must therefore be checked according to the obligation concerned.
No. TicketBAI remains applicable to the taxpayers concerned in the historical territories of the Basque Country, under the relevant foral rules.
The VeriFactu regulation does not, by itself, make the use of Peppol mandatory. The network may nevertheless be useful for interoperability in international electronic exchanges. It is necessary to check separately whether the systems in use satisfy the Spanish B2B invoicing requirements: using Peppol does not automatically demonstrate compliance with the national framework.
In summary, Spain already has a structured electronic invoicing framework based on Facturae for certain B2G transactions, SII for VAT record submission and RRSIF for the invoicing computer systems within scope.
Following an initial postponement of the deadlines to 2027, on 5 October 2026 the Spanish Ministry of Finance announced its intention to defer the remaining RRSIF obligations until October 2028, in order to bring this timetable more closely into line with that for B2B electronic invoicing. This proposed change still needs to be followed from a legal perspective.
At the same time, the B2B reform now has a published regulatory framework. Royal Decree 238/2026 and Order HAC/1028/2026 govern electronic invoice exchanges between businesses and professionals, the role of private platforms, the AEAT’s public solution and the use of structured formats. The general deadlines are 6 October 2027 for businesses exceeding the specified tax threshold and 6 October 2028 for other businesses and professionals within scope.
For businesses, the challenge is therefore not limited to choosing compatible software. They must also determine which regime applies, secure invoicing data, check existing transaction flows, prepare for B2B obligations and monitor official technical specifications. Early preparation remains essential to limit risks, additional costs and penalties.
Businesses in Spain must prepare for new compliance requirements arising from the regulation governing computerised invoicing systems (SIF), of which VeriFactu is one of the available compliance methods. Initially scheduled for 2026, the obligation to adapt invoicing systems was postponed to 2027. On 5 October 2026, the Spanish Ministry of Finance announced its intention to postpone certain obligations until October 2028. However, this revised timetable remains subject to formal adoption of the relevant provisions.
Prečítajte si viac
Do roku 2030 budú musieť všetky európske firmy prejsť na e-fakturáciu. Koniec posielaniu PDF súborov e-mailom! Nahradia ich štandardizované formáty, certifikované platformy a elektronický daňový reporting. Reforma je už v plnom prúde. Prečítajte si tento článok a zistite, ako tejto strategickej zmene porozumieť, ako ju predvídať a úspešne ju zvládnuť.
Prečítajte si viac
Lyon, Francúzsko – 24. marca 2025 – s radosťou oznamujeme naše partnerstvo so spoločnosťou Yooz, expertom na digitalizáciu a automatizáciu procesov od nákupu po platbu (P2P).
Prečítajte si viac