Spain has two overlapping invoicing obligations coming into force at different times. Verifactu governs the software you use to issue invoices. The mandatory B2B electronic invoice governs the format and exchange of the invoice document itself. Both apply to most businesses, but they solve different problems, have different deadlines, and carry different penalties.
This guide explains what each rule requires, where they overlap, and how to handle both with a single setup.
Verifactu is a technical standard for invoicing software. It does not change what goes on an invoice. It changes the software that creates the invoice.
Under the Verifactu rules (Royal Decree 1007/2023), any billing system used by a business or autónomo must be a certified invoicing system (SIF). A certified system must:
The real-time transmission to the AEAT is optional. The integrity controls, the chaining, and the QR code are mandatory for all businesses using invoicing software.
The deadline is 1 July 2027 for companies and autónomos alike.
The mandatory B2B electronic invoice (under Ley 18/2022, Crea y Crece) requires that invoices exchanged between businesses use structured machine-readable formats rather than PDFs or paper. It does not regulate the software. It regulates the document.
Three things are required:
The timeline is set by a Ministerial Order that is still pending as of mid-2026. Once published, large companies (over €8 million turnover) have 12 months to comply. Smaller businesses and autónomos have 24 months. State reporting for smaller entities adds one further year beyond that.
Verifactu is about the integrity of your billing software. The B2B electronic invoice is about the format of the document your software produces.
A business could theoretically have Verifactu-compliant software that still issues PDFs to clients. That would satisfy Verifactu but not the B2B e-invoice requirement once that obligation activates. Equally, a business could exchange structured XML invoices with clients without having Verifactu-certified software, which would satisfy the e-invoice format requirement but violate Verifactu once its deadline passes.
In practice, both requirements apply to most businesses. The right approach is software that handles both.
Verifactu applies to:
The B2B electronic invoice applies to:
An autónomo who sells exclusively to consumers must comply with Verifactu (because they use billing software) but is outside the scope of the mandatory B2B e-invoice.
Verifactu:
Mandatory B2B electronic invoice:
Verifactu has a fixed date. The B2B e-invoice dates depend on when the Ministerial Order is published.
Verifactu penalties can reach €50,000 per year for businesses using non-certified billing software after the deadline.
Mandatory B2B electronic invoice penalties carry a maximum fine of €10,000 for businesses that fail to offer e-invoicing to their customers. Additional tax and administrative penalties may apply for failure to maintain compliant records.
The Verifactu penalty is substantially higher and applies regardless of transaction type.
The two rules are complementary and most businesses will need to meet both.
A structured invoice in UBL or Facturae satisfies the B2B e-invoice format requirement. If the software that produced that invoice is also a certified SIF with chaining and QR codes, it satisfies Verifactu. One piece of software, properly set up, covers both.
The public e-invoicing platform receives the UBL copia fiel for every B2B transaction. It does not intersect with the Verifactu QR code or real-time AEAT feed, which are separate channels.
Neither rule affects B2G invoicing, which has been mandatory since 2015 under Ley 25/2013. B2G invoices go through FACe in Facturae format and are unaffected by either the Verifactu or Crea y Crece timelines.
Once the Ministerial Order is published and your deadline approaches, the setup that covers both obligations is:
Starting with software that already handles both rules avoids a second migration when the B2B e-invoice deadline arrives.
Is Verifactu the same as the electronic invoice? No. Verifactu regulates the integrity of your billing software. The mandatory electronic invoice regulates the format and exchange of the invoice document. Both apply to most businesses but under different rules and timelines.
Which rule has the earlier deadline? Verifactu has a fixed deadline of 1 July 2027. The B2B electronic invoice deadline depends on when the Ministerial Order is published. For large companies, that could also fall around late 2027, making them roughly simultaneous. For smaller businesses and autónomos, the B2B deadline is likely 2028 or later.
Do autónomos need to comply with both? Autónomos who invoice other businesses: yes, both. Autónomos who sell only to consumers: Verifactu applies (because they use billing software), but the B2B electronic invoice does not.
Does the B2B e-invoice replace Verifactu? No. They are separate obligations under separate regulations. The B2B e-invoice does not satisfy Verifactu, and Verifactu does not satisfy the B2B e-invoice.
What format should I use for the electronic invoice? UBL is the most interoperable choice and the format required for the copia fiel to the public platform. Facturae is the existing Spanish standard and remains valid. See mandatory electronic invoice for the full format guide.
When does the Ministerial Order come out? The second public consultation draft closed in April 2025. No publication date has been confirmed. The working planning assumption is late 2026.
renn's invoicing tool is built to be both Verifactu-compliant and B2B e-invoice-ready from day one, covering certified SIF requirements, UBL generation, the copia fiel, and state reporting as the Ministerial Order activates deadlines. For the full detail on each obligation, see the Verifactu guide and the mandatory electronic invoice guide. If you are setting up as an autónomo, renn handles autónomo registration online and covers both invoicing obligations from there.
