Verifactu and E-Invoicing in Spain: The Real Timeline and What to Do Now

Mentioning Verifactu and e-invoicing in the same breath causes a lot of confusion, because they are two separate obligations with different timelines. One aims to make invoicing software tamper-proof; the other requires invoices between businesses to travel in electronic format. Here is what each one requires, who it affects, and what you should do in this final stretch of 2026.

Two rules, two goals

Verifactu comes from Spain’s anti-fraud law (Law 11/2021), which requires invoicing software to guarantee the integrity, preservation, accessibility, legibility, traceability and inalterability of records. It is implemented through a regulation approved in 2023 and a ministerial order from 2024 setting out the technical specifications. In practice, every invoice generates an invoicing record with a chained hash, so deleting or altering an invoice leaves a trace.

Business-to-business e-invoicing comes from Law 18/2022, known as the “Crea y Crece” law. It requires businesses and professionals to issue, transmit and receive invoices in a structured electronic format for B2B transactions. A PDF sent by email does not count as an electronic invoice for these purposes. In addition, systems will have to allow payment status to be tracked.

They are not the same thing: you can comply with one and not the other. A piece of software may be Verifactu-compatible and still need to prepare for the structured electronic format, and the other way around.

The real timeline: which deadlines apply, and to whom

The Verifactu timeline has been postponed more than once. The current reference is the extension approved at the end of 2025: Corporate Income Tax taxpayers become subject to the obligation from January 2027, and all other obligated parties (freelancers included) from July 2027. Since the dates have moved before, always check the rules currently in force on the Spanish Tax Agency (AEAT) website before treating anything as settled.

For B2B e-invoicing, the obligation depends on the entry into force of the implementing regulation. Once it is in force, the law provides a shorter adaptation period for larger companies (turnover above eight million euros) and a longer one for everyone else, including freelancers and SMEs. Smaller businesses get somewhat more leeway, but not an exemption.

Keep in mind, too, that there are exceptions and special regimes. For example, those already on the immediate supply of VAT information system (SII) or under the regional tax systems of the Basque Country and Navarre are treated differently. If you fall into one of those cases, review it with your advisor.

Invoicing software: what to do now

The obligated party is whoever uses the software, but technical responsibility lies with whoever produces it: the vendor must issue a statement of compliance (declaración responsable) confirming that its software meets the requirements. There is no “official certificate” to buy separately; what you should ask for is that statement, and check that the product covers it. One key question: will your software run in Verifactu mode (each invoice sent to the AEAT) or in non-Verifactu mode, with records kept and signed internally? Both are valid as long as the software complies.

A sensible checklist for now:

1) Identify what you invoice with today, including spreadsheets, Word documents or templates: these tools, as they are normally used, will hardly be compliant.
2) Ask your vendor in writing whether an updated version is already available, when, and at what cost.
3) Review how you issue, correct and cancel invoices: corrective invoices and cancellations must be recorded, not “deleted”.
4) If you receive invoices from suppliers, think about how you will handle them in electronic format.
5) Decide with your advisor which mode (Verifactu or not) suits you best.

Common mistakes: waiting until the last quarter before the deadline, assuming “my software will take care of it” without asking for confirmation, keeping a parallel invoicing system with no controls, or editing invoices that have already been issued instead of correcting them. The penalty regime under the anti-fraud law is serious, both for those who produce non-compliant software and for those who use it.

At Zythos Business we support freelancers and SMEs through this transition: we review how they invoice today, which software fits them and when each obligation applies, so that adapting is an orderly process rather than a last-minute emergency. If you want to know where you stand, start by reviewing your current system and get in touch with us.