Spain has two mandates that people often mix up. Verifactu sets anti-fraud rules for billing software. B2B electronic invoicing under the Crea y Crece law sets rules for the invoice itself and how it moves between companies. This guide explains the difference between Verifactu and electronic invoice, what each one does, when they start, who is in scope, and how to comply with both using one stack.
Quick Q&A
What is Verifactu in one line? Rules for billing systems to create tamper-evident records for every invoice, with a QR code and optional real-time send to AEAT (Agencia Tributaria, Spain's Tax Agency).
What is B2B electronic invoicing? Structured e-invoices sent through networks, with status messages and payment reporting.
Do they replace each other? No. They solve different problems and will run together.
Are Verifactu records the same as an e-invoice? No. They are not invoices. They are records made by the billing system that prove the invoice existed and is unchanged.
Do all invoices need a QR code? Yes, if issued with a system in scope. For structured e-invoices, you embed the QR data instead of printing a QR image.
If I am in SII, do I adopt Verifactu? No, not for your own invoicing. But you will still issue and receive B2B e-invoices when the regulation is in force.
Is VERI*FACTU mode mandatory? No. You can choose NO VERIFACTU with strong local controls. VERI*FACTU adds real-time remittance and enables recipient verification.
Difference between Verifactu and electronic invoice (quick win)
Object: Verifactu controls the billing software and its invoice records. B2B electronic invoicing controls the invoice document and its exchange between businesses.
Scope/recipients: Verifactu affects all invoices issued with software - B2B and B2C - complete or simplified - except (1) SII filers (SII is the Immediate Supply of Information, Spain's real-time VAT books system), (2) businesses that issue all invoices manually (no SIF), and (3) taxpayers under Basque/Navarre foral tax competence. B2B e-invoicing applies only to business-to-business operations.
Formats: Verifactu defines a record format called "registro de facturación" with security fields and a QR code. The invoice itself can be paper, PDF, or electronic. B2B e-invoicing requires structured e-invoices. The public solution uses Facturae (Spain's structured XML, a computer-readable file format, for e-invoices). Private platforms can agree other syntaxes as long as they interconnect.
Transport: Verifactu either keeps records locally (NO VERIFACTU) or sends them in real time to AEAT (VERI*FACTU). B2B e-invoicing exchanges invoices via private platforms that interconnect and the Public e-Invoicing Solution. If you invoice through a private route, you must also send a faithful Facturae copy to the public solution.
Statuses/payments: Verifactu focuses on immutability and traceability of records. It does not define commercial status flows. B2B e-invoicing introduces invoice status messages and mandatory payment reporting, like sending the effective payment date.
Start dates: Verifactu users start on 1 Jan 2026 for corporate income tax payers and 1 Jul 2026 for the rest. B2B e-invoicing starts after the final B2B regulation is published: companies with over €8M turnover have 1 year, the rest 2 years.
Exclusions: Verifactu excludes SII filers for their own invoicing. B2B e-invoicing covers B2B only, not B2C.
Penalties: Verifactu sets fixed fines for dual-use or non-compliant software and for users that use or keep it. B2B e-invoicing sets duties to issue and receive e-invoices and to report payments. Non-compliance may be fined and also monitored under late-payment rules.
What is Verifactu? (anti-fraud billing-software rules)
Legal base: Article 29.2.j LGT (General Tax Law) authorizes this and RD 1007/2023 (RRSIF) sets the rules. A Ministerial Order will define the technical specs, and RD 254/2025 updates the dates.
Plain idea: Your billing program must create a tamper-evident record for each invoice. Think of it as a fingerprint plus an event log. It is not the invoice. It is a separate record that proves the invoice existed and was not hidden or altered.
QR and legend: Every complete or simplified invoice must include a QR code (a square barcode you can scan). If you operate in VERI*FACTU mode, you also print the legend "Factura verificable - VERIFACTU" so the recipient knows the record is in AEAT. The QR lets people verify or notify the data to AEAT.
Two modes:
- VERI*FACTU mode: the system sends the record in real time to AEAT. Recipients can check "found" or "not found".
- NO VERIFACTU mode: the system keeps the record locally with a digital signature and an event log. Recipients can communicate the QR contents to AEAT, but it will show as "not verifiable" because it is not pre-sent.
Who is in scope ?
Almost all businesses that issue invoices with software and are domiciled in common-territory Spain.
Excluded: taxpayers in SII for their own invoicing. Also excluded: operations where the ROF authorises no invoice or an alternative document instead of an invoice - for example, sector-specific tickets/receipts like public transport, parking/tolls, or vending machines (ROF is the invoicing regulation in RD 1619/2012).
Deadlines: Users go live on 1 Jan 2026 if they pay corporate tax, and 1 Jul 2026 for the rest, including most autónomos. Software makers had until 29 Jul 2025 to deliver compliant versions.
AEAT free app: AEAT will offer a lightweight VERI*FACTU app for low-volume issuers. It prints invoices with a QR and stores the record at AEAT.
What changes on invoices ?
You add the QR code, or embed the QR information in electronic formats. You show the legend when in VERI*FACTU. Content rules still come from the ROF in RD 1619/2012.
Penalties in simple words
There are fixed fines for building or selling dual-use software and for using or keeping it. Users must deploy compliant software.
Authority reference: see the official state bulletin site for the legal texts BOE (Spain's Official State Gazette).
More details about Verifactu here.
What is electronic invoicing under Crea y Crece (B2B)?
Legal base: Ley 18/2022, known as Crea y Crece. A specific B2B e-invoice regulation will set formats, networks, and deadlines. Drafts confirm a public solution run by AEAT, Facturae syntax when using that solution, inter-platform interconnection, and mandatory status plus payment reporting - for example, reporting the effective payment date within a few days.
Scope: B2B only. That means invoices between businesses or professionals. Consumer sales are outside this mandate.
Formats and networks: You may use private platforms or the Public e-Invoicing Solution. Private platforms must interconnect. If you do not issue via the public solution, you must still send a faithful Facturae copy of each invoice to it. Facturae is Spain's structured XML for e-invoices used by the public sector.
Statuses: Recipients must send acceptance or rejection messages and later report payment status.
Deadlines: Companies with over €8M turnover must comply 1 year after the regulation is published. Everyone else has 2 years after publication. The exact calendar depends on the BOE publication date.
Policy goals: Cut late payments, improve traceability and liquidity, and digitise B2B trade.
Verifactu vs electronic invoice - side by side
Purpose: Anti-fraud control of software and records vs digitalisation of invoices and payments.
What moves: Verifactu moves records. B2B e-invoicing moves invoices and status or payment messages.
Recipients: Verifactu touches all invoices made with software, B2B and B2C. B2B e-invoicing touches only B2B.
Format: Verifactu uses a record format plus a QR code. The invoice can be paper, PDF, or electronic. B2B requires a structured e-invoice - in the public solution, Facturae - plus status and payment data.
Transport: Verifactu can send records to AEAT in real time or store them locally. B2B uses private platforms and the public solution. If you invoice privately, a faithful Facturae copy also goes to the public solution.
Timelines: Verifactu is fixed - Jan or Jul 2026. B2B is relative - 1 to 2 years after the final regulation is published.
Exclusions: Verifactu excludes SII filers. B2B covers all B2B, including SII companies.
Penalties: Verifactu sets fixed fines for non-compliant or dual-use software, both for makers and users. B2B fines relate to issuing or receiving e-invoices and reporting payment, and link to late-payment oversight.
Timelines and entry into force
Verifactu
- Software makers: compliant releases delivered by 29 Jul 2025.
- Users who must issue invoices: 1 Jan 2026 for corporate tax payers, 1 Jul 2026 for the rest.
Electronic invoicing (B2B)
- Trigger: publication of the final B2B regulation in the BOE (Spain's Official State Gazette).
- Over €8M turnover: 1 year after publication.
- €8M or less: 2 years after publication.
- Heads-up: exact dates depend on BOE publication.
How they work together in practice
Outbound - you to client: Your billing system issues the invoice and creates the Verifactu record with a QR code. If you choose VERI*FACTU mode, the record goes to AEAT in real time. For B2B recipients, you also send a structured e-invoice through your platform and, if you did not use the public route, the public solution gets a faithful Facturae copy.
Inbound - supplier to you: You receive a structured e-invoice, send status messages, and report the effective payment to the public solution within the allowed window.
Books and returns: Verifactu records help you prepare VAT books and pass audits. B2B payment reporting helps you meet late-payment rules.
SII companies: Keep using SII. You are excluded from Verifactu for your own invoicing but still within B2B e-invoicing once the regulation applies.
Compliance checklist for both regimes
- Choose software adapted to RD 1007/2023 that supports VERIFACTU and NO VERIFACTU.
- Enable QR on all invoices, or embed the QR data in structured e-invoices. Print the legend when in VERI*FACTU.
- Decide your mode: VERI*FACTU for real-time remittance, or NO VERIFACTU with local storage, signatures, and a full event log. For low volume, consider AEAT's free app.
- Prepare B2B e-invoicing: pick a platform or use the public solution. Ensure Facturae support, interconnection, status messages, and payment APIs. If you invoice via a private route, plan the faithful Facturae copy to the public solution.
- Map timelines: go live by Jan or Jul 2026 for Verifactu. Plan a 1 to 2 year runway after B2B regulation publication.
- Governance: version control, audit logs, user rights, and no dual-use features. Use corrective records, not overwrites.
- Training: teach teams to read the QR, handle statuses, and report payments on time.
Penalties and audits
Verifactu: Fixed fines for users who use or keep alterable or non-compliant software, and higher fixed fines for developers or distributors who build or market dual-use or non-conforming systems. There are also fines tied to certification or procedural breaches.
B2B e-invoicing: Duties to issue and receive e-invoices, to keep access to past invoices for ex-clients, and to report payment or rejection. Non-compliance may be fined and counted in late-payment oversight using the 60-day rule.
Cash-payment cap context: Spain's anti-fraud rules also limit cash in business deals. That is separate, but useful context when you compare regimes.
Full article about Anti-fraud law available here.
Final decisions before rollout
Pick your Verifactu mode: Choose VERI*FACTU if you want real-time remittance to AEAT and easy recipient verification. Choose NO VERIFACTU if you prefer local storage with signatures and full logs because of offline sites or strict IT policies. Document the fallback for AEAT outages and who checks "found/not found" when clients scan the QR.
Choose your B2B rails: Decide whether you will issue through the Public e-Invoicing Solution or a private platform. If you use a private route, plan the faithful Facturae copy to the public solution. If you trade cross-border, make sure your provider supports interconnection beyond Spain and can translate formats without losing data.
Map the data you must capture and show: Put the QR on every invoice or embed its contents in the e-invoice. Implement acceptance/rejection status messages and capture the effective payment date within the allowed window. Keep access for ex-clients to their past invoices and store records safely for audits.
Run a pre-go-live test: Generate sample invoices and records, scan the QR to confirm "found" in VERI*FACTU and "not verifiable" in NO VERIFACTU, and test inter-platform delivery. Verify that the public solution accepts your Facturae copy and that payment-status updates land correctly.
Pitfalls to avoid: Thinking a PDF alone counts as B2B e-invoicing, forgetting the Facturae copy when using private rails, mixing SII with Verifactu for your own invoicing, and training only finance while sales or ops also issue invoices.
Bottom line
Think of Verifactu as the anti-fraud spine of your billing system - records plus a QR code - and B2B e-invoicing as the network layer that moves structured invoices and payment statuses. Implement both: Verifactu by Jan or Jul 2026. Then roll out B2B e-invoicing on the 1 to 2 year timeline that starts on publication of the final regulation. If you remember nothing else, remember this difference between Verifactu and electronic invoice so you set up one stack that meets both.
