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Spain's e-invoicing regulation timeline

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Executive summary

In Spain, e-invoicing compliance is governed by a complex, regionally differentiated system designed to ensure transparency, prevent fraud, and align with EU digitalization standards. The country relies on multiple overlapping frameworks rather than a single unified system, reflecting both regional fiscal autonomy and incremental regulatory evolution. VERI*FACTU is already available and will become mandatory for all invoices starting January 1, 2027, except for companies already reporting via SII or TicketBAI. It requires digitally signed invoices, a QR code linking to AEAT verification. Crea y Crece (RD 238/2026) introduces mandatory structured B2B e-invoicing through a new public/private platform system, rolling out in phases starting ~12 months after the upcoming Orden Ministerial (expected late 2026). TicketBAI applies in the Basque Country (Álava, Bizkaia, Gipuzkoa) and mandates certified software for digitally signed XML invoices, including QR codes and unique identifiers. Facturae is required for B2G transactions. XML invoices are reported through the FACe platform. SII mandates near-real-time VAT reporting for large companies and select taxpayers. This article also provides insight and further resources to understand invoice regulation in Spain.

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Invoicing in Spain

Spain’s numerous invoicing and reporting systems stems from its decentralized fiscal structure, where regions like the Basque Country and Navarra manage their own tax authorities, alongside the national AEAT. Instead of a unified reform, Spain has evolved through incremental, purpose-specific initiatives. This layered approach reflects the country’s effort to balance regional autonomy, EU digitalization mandates, and the fight against tax fraud, but it has produced a patchwork of systems that coexist under overlapping jurisdictions.
  • VERI*FACTU enforced in 2027, required for self employed individuals and companies not covered by SII or TicketBAI.
  • Crea y Crece introduces mandatory B2B e-invoicing through a new public/private platform system, rolling out in phases following the upcoming Orden Ministerial.
  • TicketBAI required for issuers with tax obligations to the foral agencies of Ávala, Biskaia and Gupizcoa.
  • Facturae is required when businesses invoice Spanish public administrations (B2G), requiring invoices in XML format submitted through the FACe platform.
  • SII mandates near-real-time reporting of invoice data to the Spanish Tax Agency (AEAT) for large companies.

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Spain

VERI*FACTU will be mandatory for companies from January 1st, 2027. The rest of tax payers from 1 July 2027. Companies reporting with SII or TicketBAI are exempt from reporting with VERI*FACTU.
Spain’s upcoming e-reporting and fiscalization regulation requiring businesses to use approved software that records and digitally signs each invoice to ensure transparency and prevent fraud. The format requires a QR code which links to the online verification service of the AEAT.
ScopeB2C, B2B, B2G
FormatVERI*FACTU (XML)
ComplianceFiscalization and e-reporting (not e-invoicing)
InfrastructureHybrid: public and private platforms
ModelReal Time Invoice Reporting and fiscalization
Effective dateMandatory for businesses issuing B2C, B2B, B2G invoices from Jan 1, 2027
AgencyAEAT
Invopop SupportVERI*FACTU Spain App
https://assets.invopop.com/apps/verifactu/icon.svg

VERI*FACTU Spain

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Ley 18/2022 (“Crea y Crece”) mandates structured electronic invoicing for all B2B transactions in Spain. The technical framework is set out in Real Decreto 238/2026 (in force since 20 April 2026). Effective deadlines depend on the upcoming Orden Ministerial: companies with turnover above €8M will have 12 months from the OM’s entry into force, and all other businesses 24 months.Invoices must follow the EN 16931 semantic model, carry a unique identifier, and be signed with an advanced electronic signature. They are exchanged either through the AEAT’s new free Solución Pública de Facturación Electrónica or through interoperable private platforms — which must additionally send a UBL “copia fiel” of each invoice to the Solución Pública at the moment of issuance. Recipients must report acceptance/rejection and effective payment within 4 calendar days (excluding Saturdays, Sundays, and national holidays).Crea y Crece is distinct from VERI*FACTU: VERI*FACTU regulates invoicing software and tax-agency reporting; Crea y Crece regulates how B2B invoices are exchanged between businesses.
ScopeB2B
FormatEN 16931–compliant: Facturae, UBL (incl. Peppol BIS), CII, EDIFACT
ComplianceE-invoicing and invoice-state reporting
InfrastructureAEAT Solución Pública + interconnected private platforms
ModelDecentralised exchange with mandatory UBL copy to AEAT
Effective date~12 months after the Orden Ministerial enters into force for businesses with turnover > €8M; ~24 months for all others
AgencyAEAT (technical), Ministerio de Economía / Ministerio de Hacienda (regulatory)
Invopop supportTBD
Facturae is the Spanish XML-based format for electronic invoices used in B2G transactions. It requires a digital signature and aligns with EN 16931 (EU) for electronic invoicing. Invoices in Facturae format are submitted at FACe, a centralized government platform. Note that the supplier must issue a VERI*FACTU or TicketBAI invoice in addition to the Facturae invoice.
ScopeB2G
FormatFacturae
Compliancee-invoicing and e-reporting
InfrastructureFACe
ModelCentralized
Effective dateMandatory for companies issuing invoices to public authorities since 2017
AgencyAgencia Estatal de Administración Tributaria (AEAT)
Invopop supportFacturae Spain App (invoicing, reporting done through FACe)
https://assets.invopop.com/apps/facturae/icon.svg

Facturae Spain

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Companies reporting to TicketBAI or SII are exempt from issuing VER*FACTU

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Álava, Gipuzkoa and Bizkaia

Spain’s Haciendas Forales are the provincial tax authorities of the Basque Country (Álava, Bizkaia, and Gipuzkoa), which possess unique fiscal autonomy under the Spanish Constitution. These provinces manage variations of the TicketBAI standard which Invopop simplifies. Read our comprehensive article What is the TicketBAI regulation in Euskadi? for more information.
TicketBAI is the Basque Country’s electronic invoicing and anti-fraud system. It requires businesses to use certified software that generates a digitally signed XML file for every invoice and automatically sends it to the corresponding provincial tax authority (Álava, Bizkaia, or Gipuzkoa). Each invoice must also include a QR code and TBAI identifier, allowing verification by both customers and tax inspectors. Full compliance now mandatory across the Basque Country.
ScopeB2C, B2B, B2G
FormatTicketBAI (XML)
InfrastructureHybrid system: Public solution and private platforms
Compliancee-invoicing and e-reporting
ModelReal Time Invoice Reporting
RegionÁlava, Bizkaia and Gupizkoa
Effective dateSince January 1st, 2022
AgenciesAgencia Foral de Gupizkoa
Hacienda Foral de Álava
Hacienda Foral de Bizkaia
Invopop supportTicketBAI Spain App
https://assets.invopop.com/apps/ticketbai/icon.svg

TicketBAI Spain

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Upcoming format/reporting announced in September 2025 by the tax authorities of Navarra. The government has not published information about this implementation, but has stated that it will be based on TicketBAI and VERI*FACTU. Details and Invopop support will be announced once the technical specification is made available.
Upcoming format/reporting announced in September 2025 by the tax authorities of Navarra. The government has not published information about this implementation, but has stated that it will be based on TicketBAI and VERI*FACTU. Details and Invopop support will be announced once the technical specification is made available.

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E-reporting

Involves sending invoice data to tax authorities in real-time or near real-time, typically as part of government initiatives to improve tax compliance and reduce VAT fraud.
SII allows AEAT to receive VAT-related information almost in real time. It aims to reduce errors in VAT declarations, improve fraud detection, and streamline administrative reporting. Obligatory for large companies with an annual turnover > €6 million and optional for smaller companies that want faster reconciliation with the Tax Agency.
ScopeB2C, B2B, B2G
FormatSII (XML)
ComplianceFiscalization and e-reporting
Effective dateMandatory since 2017
NotesApplies to large companies (turnover exceeding €6,010,121.04 in the previous year), VAT groups, and those registered in the REDEME (Monthly VAT Refund Register).
AgencyAEAT
Invopop supportSpain App
https://assets.invopop.com/apps/gov-es/icon.svg

Spain

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Regulation

Complete (B2B) Invoice
  • Invoice number and series (where applicable). The numbering of invoices within each series shall be consecutive.
    • Series for the following invoices are mandatory:
      • Those issued by the customers or by third parties (each needs its own series).
      • Correction invoices (Credit/Debit notes).
      • In forced collection proceedings, invoices issued by winning bidders who are business owners or professionals .
  • Issue date.
  • Full name or complete business name of both the party issuing the invoice and the customer.
  • Tax ID Number assigned by the Spanish tax authorities or another EU Member State. The customer’s Tax ID Number must also be included when:
    • It’s a tax-exempt sale of goods between EU countries.
    • The customer is responsible for paying the tax on the transaction.
    • The transaction takes place within the Spanish tax territory (TAI), and the business owner or professional issuing the invoice is considered to be based in that territory.
  • Address of both the party issuing the invoice and the customer.
  • Description of the goods or services, including all information needed to calculate the taxable amount, such as the unit price before tax, and any discounts or reductions not already included in that unit price.
  • The tax rate or rates applied to the transactions.
  • The tax amount being charged, which must be shown separately.
  • The date when the transactions took place or when advance payment was received, if different from the invoice date.
  • In sales of new vehicles, the first use date and the distance traveled or hours of navigation or flight up to delivery.
  • If any of the following apply, it must be mentioned: tax-exempt transaction, customer issues the invoice, reverse charge (customer pays the tax), Travel Agency special scheme, or second-hand goods special scheme
Simplified Invoice
  • Number and, if relevant, series.
  • Date of issue.
  • Date of the transaction if different from the issue date.
  • Tax ID Number (NIF) and full name or business name of the issuer.
  • Description of the goods delivered or services provided.
  • Tax rate, and optionally the phrase “VAT included”
  • Total amount.
  • For correction invoices, reference to the invoice being corrected.
  • If any of the following apply, it must be mentioned: tax-exempt transaction, customer issues the invoice, reverse charge (customer pays the tax), Travel Agency special scheme, or second-hand goods special scheme.
The tax authority may require additional information in certain situations, but this can never exceed what’s required for a complete invoice. In certain situations it may authorize that simplified invoices that don’t include some of the above requirements. These authorizations must be properly published.
You don’t have to issue invoices in the following scenarios:
  1. Tax-exempt transactions under Article 20 of Law 37/1992, with some exceptions: you still need to invoice for healthcare and hospital services, property sales, and goods exempt because you couldn’t claim back the VAT you paid.
  2. If you’re under the Equivalence Surcharge Regime (a special VAT system). However, you must invoice for property sales that aren’t tax-exempt (unless they’re part of enforcing a guarantee).
  3. If you’re under the Simplified Tax Regime, unless your tax is calculated based on how much you earn. You still need to invoice when selling fixed assets.
  4. Other cases where the Tax Agency gives you permission - they might waive the invoice requirement for certain industries or specific companies to keep business running smoothly.
Important: Even in these four cases, you must issue an invoice if:
  • Your customer is a business/professional or a private individual who needs it for tax purposes
  • You’re selling to another EU country
  • You’re exporting goods
  • Your customer is a government body or a legal entity that isn’t acting as a business
  1. If you’re in farming, livestock, or fishing under the special regime for those sectors. You’ll need to issue an “agricultural receipt” for compensation reimbursements if you bought from others in the same regime. You always need to invoice for property sales.
  2. Financial and insurance transactions - no matter who you’re dealing with, even other businesses. Exception: you do need to invoice for taxable transactions (that aren’t exempt) in mainland Spain, the Balearic Islands, or another EU country.
The archival period of invoices dictated by the AEAT is the following:
  • 4 years: This is the minimum general requirement for most invoices for tax purposes. Starting from the date for filing the corresponding tax return, according to General Tax Law 58/2003.
  • 6 years: Commercial regulations require you to keep business documentation for 6 years, including invoices, correspondence, and supporting documents, under Article 30 of the Commercial Code.
  • 10 years (or longer): Some special cases require longer retention periods:
    • Capital assets/investments: Must be kept for up to 10 years.
    • Public grants: Invoices related to EU public funding may need to be kept for up to 10 years, depending on European regulations.
    • Legal disputes or inspections: You may need to keep invoices longer if there’s an ongoing lawsuit or tax inspection, such as in cases of tax fraud.
There is no official certification for VERI*FACTU from the AEAT (the Spanish tax agency). Instead, each developer, company, or provider that implements an invoicing software must provide an electronically signed declaration where they certify that their system meets all the requirements established in the regulations. This document is binding and must be kept available for the Tax Authority.The AEAT requires that this declaration be available and always visible within the system itself, and it must include certain control elements such as the installation number, issuer data, software version, and system ID.If you are a white label user of Invopop (you issue invoices in the name of third parties), you are required to display a link to this “declaración responsable” in your software. Here is the template from the AEAT, and our own for your reference: Declaración responsable VERI*FACTU - Invopop. Some of our customers have asked us if it is necessary to mention Invopop in their declaración responable. It is not required, but we appreciate it.
The Spanish Tax Agency (AEAT) requires that companies formally authorize Invopop to issue invoices on their behalf. To comply with this regulation, the supplier’s legal representative must sign an agreement granting Invopop the necessary consent to generate and manage invoices in their name. This signed authorization ensures that all invoicing activities carried out by Invopop are legally valid and recognized by the AEAT.For this process, the supplier can sign the agreement PDF with a valid digital certificate, such as one issued by the FNMT, or a handwritten signature with a company stamp (sello de empresa), in which case the user must provide a valid ID such as DNI, NIE or passport. In the case of self-employed individuals (autónomos) a company stamp is not required.View the representation agreeement process.
Autónomo (Self-employed individual)An autónomo’s NIF is simply their DNI or NIE:
  • DNI (Documento Nacional de Identidad) — for Spanish nationals. Format: 8 digits + 1 letter (e.g., 12345678A)
  • NIE (Número de Identidad de Extranjero) — for foreign residents. Format: 1 letter + 7 digits + 1 letter (e.g., X1234567A)
Since an autónomo operates as a natural person (not a separate legal entity), their personal ID number is their tax number. There’s no distinction between the person and the business.Company (Sociedad / Legal entity)A company has a CIF (Código de Identificación Fiscal), which is now technically also called a NIF but for legal entities. Format: 1 letter + 7 digits + 1 control character (letter or digit) (e.g., B12345678)The first letter indicates the type of entity:
  • A — Sociedad Anónima (S.A.)
  • B — Sociedad Limitada (S.L.) — the most common
  • C — Sociedad Colectiva
  • G — Associations / Foundations
  • N — Foreign entities
  • P — Local government bodies
  • Q/S — Public bodies
  1. VAT (IVA: Impuesto sobre el Valor Añadido)
  • Standard: 21%
  • Reduced: 10%
  • Super-reduced: 4%
  • Each of these can include an Equivalence Surcharge for retailers (eqs).
  • Variants exist for special sectors, e.g., agriculture, modules.
  1. IGIC (Impuesto General Indirecto Canario)
  • Zero: 0%
  • Reduced: 3%.
  • General: 7,00%
  • Incremented: 9,5% and 15,0%
  • Special: 20%
  1. IPSI (Ceuta & Melilla)
  • General: 4% Melilla, 3% Ceuta
  • Reduced: 0,5%
  • Incremented: 10%
  1. IRPF Rates (Personal Income Tax)
  • Professional rates: 15%
  • Professional starting rate: 7.0%
  • Rental or Interest Capital: 19.0%
  • Modules Rate: 1%
Our blog posts are comprehensively researched and a great source of information regarding electronic invoicing, reporting and fiscalization. We recommend the following reads:

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FAQ

Compliance questions Spain
Crea y Crece (Ley 18/2022, “Law on the Creation and Growth of Companies”) is a Spanish law introducing mandatory B2B electronic invoicing for all businesses and professionals established in Spain.Its primary policy goal is combating late payments. Spain has one of the longest average payment periods in the EU (~80 days), and the law forces structured, traceable data on every B2B invoice, plus mandatory invoice status reporting (acceptance, rejection, payment date) so payment behavior becomes visible and measurable.Key parameters as they stand now:
  • Scope: domestic B2B transactions where the recipient is a business or professional established in Spain.
  • Architecture: hybrid — a free public AEAT platform plus interoperable private platforms.
  • Format: EN 16931-compliant UBL is mandatory for the public solution and for copias fieles submitted from private platforms; Facturae, UBL, CII and EDIFACT are accepted between private platforms.
  • Timeline: Royal Decree 238/2026 was published 31 March 2026; the Ministerial Order is expected to enter force 1 October 2026, triggering the clocks — 12 months later for companies with turnover >€8M, 24 months later for everyone else, with status reporting deferred a further year for sole traders / IRPF attribution entities.
This regulation aims to transform invoicing from “PDF by email” into a structured, reportable, interoperable network.
Any entity with a Spanish NIF — companies, autónomos, and foreign entities with Spanish fiscal presence. Foreign-only entities issuing into Spain must operate through their local fiscal representation or a non-resident NIF.
Quarterly or monthly VAT (Modelo 303), annual recap (Modelo 390), recapitulative intra-EU declaration (Modelo 349), and the annual third-party transactions return (Modelo 347). Crea y Crece (2027) adds invoice status reporting (acceptance, rejection, payment date) on top.
Facturae
Mandatory for B2G transactions with Spanish public administrations above €5,000 since 2015 (Ley 25/2013). Voluntary for B2B today; will become broadly mandatory once Crea y Crece’s implementing decree takes effect (currently expected 2027).
For B2G submissions, the supplier needs a valid digital certificate recognized by FACe (Cl@ve, FNMT, etc.). For Invopop-generated XAdES signatures the certificate is Invopop’s own; suppliers using their own signing flow upload theirs.
No-VERI*FACTU
“No-VERI*FACTU” is the alternative compliance mode under the same Spanish billing-software regulation (Reglamento de Sistemas Informáticos de Facturación). Invoices are not sent to AEAT in real time; instead they are registered locally in the certified system and may be inspected on demand. Suitable for businesses that prefer to keep records private unless asked.
Same fiscal residence requirements as VERI*FACTU. Additionally, the supplier must be able to produce the chained register on AEAT request, Invopop retains it indefinitely on their behalf.
SII
SII (Suministro Inmediato de Información) is mandatory for taxpayers that file VAT on a monthly basis. In practice this includes companies with annual turnover above €6,010,121.04, members of VAT groups (REGE), and businesses registered in the monthly VAT refund register (REDEME). Other taxpayers can opt in voluntarily.
The supplier must be a Spanish-resident taxpayer subject to SII (turnover > €6M, REGE, or REDEME) or have voluntarily opted in. They must hold a digital certificate for AEAT or appoint Invopop as their representative via signed agreement.
Issued and received invoices must be reported within 4 calendar days. Subsequent corrections, cancellations, and intra-EU operations have additional bookkeeping streams (Libro de Bienes de Inversión, Libro de Operaciones Intracomunitarias).
TicketBAI
No, you don’t need to register with TicketBAI, or upload any digital certificates to Invopop. As a certified billing provider, Invopop will sign all invoices with our own digital certificate.TicketBAI allows three types of certificates; Invopop uses the certificado sello de empresa which allows us to sign e-invoices on behalf of our customers, saving you the burden of registering and uploading certificates yourself.
  • Bizkaia: by the end of each quarter, except for companies under SII (turnover above 6 million euros), which must report within 4 days.
  • Gipuzkoa and Álava: The submission must be done immediately after generating the invoice.
The supplier must have fiscal residence in one of the three foral territories (Bizkaia, Gipuzkoa, Álava) and sign a representation agreement allowing Invopop to issue on their behalf. No supplier-side certificate required.
VERI*FACTU
Following congress approval, the VERI*FACTU mandate has been postponed by one year. The new dates are:
  • January 1, 2027 for companies
  • July 1, 2027 for self-employed individuals.
VERI*FACTU will be mandatory for companies from January 1st, 2027. The rest of tax payers (mainly self-employed indidividuals) from 1 July 2027. Companies reporting with SII (large companies) or TicketBAI are exempt from reporting with VERI*FACTU.
VERI*FACTU invoices don’t necessarily need to be printed because they are issued with electronic invoicing systems such as Invopop. Source: AEAT FAQ.
Yes, VERI*FACTU allows issue dates to be in the past, as long as they are after October 28, 2024. The issue date can’t be set with a date in the future. The AEAT is not strict about the validation, but it’s best to keep your intentions clear. GOBL gives you alternative fields such as op_date and value_date to store details about your invoicing operation.
Spanish fiscal law requires the customer to be identified with an ID document (preferably official). Set the es-verifactu-identity-type extension to 07 (“Not registered in census” / “No censado”), which maps to the IDOtro field in VERI*FACTU.Here is an example of a customer identity block in GOBL:
"customer": {
    "name": "Consumer",
    "identities": [
        {
            "label": "NIE",
            "country": "ES",
            "code": "Z1111111S",
            "ext": {
                "es-verifactu-identity-type": "07"
            }
        }
    ]
}
For the full list of identity type codes, see the es-verifactu-v1 addon documentation.
Suppliers must use a certified billing system (Invopop is one). Each supplier must sign a representation agreement allowing Invopop to issue invoices on their behalf — without a digital certificate from the supplier’s side.
More available in our Spain FAQ section

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