Ready to comply with VERIFACTU and e-invoicing in Spain? The 2025 and 2026 deadlines are approaching fast!

Time is running out! Ensure you comply with the VERIFACTU regulation!

On 6 December 2023, a regulation was published, establishing the requirements for certified billing programs used by business owners and professionals. This regulation, which is part of the Anti-Fraud Law, aims to standardise the billing process across Spain, prevent manipulation of billing records, and combat tax fraud. 

Following a a ministerial order effective from 29 October 2024, business owners and professionals have until 25 July 2025 to ensure that their invoicing programs are certified by the Tax Agency (AEAT). This means that only billing software meeting the established requirements can be used, thereby ensuring consistency and preventing fraudulent activities. 

While there is speculation that the requirement may be postponed once more, no official announcement has been made. Therefore, it is advisable for businesses to act promptly to avoid any risk of non-compliance.

What is the VERIFACTU Regulation?

The terms VERIFACTU or VERIFACTU Regulation refer to rules for billing software and the standardisation of billing record formats, approved by Royal Decree 1007/2023.

The regulation sets requirements for computerised billing systems (SIF) used by entrepreneurs and professionals in economic activities to prevent and detect fraud. SIFs must generate and save or send a summary of each invoice (invoicing register) to the Tax Agency, including security measures like digital fingerprints, data from previous registers, and electronic signatures. SIFs must include a QR code on invoices to allow easy data submission to the Tax Agency for verification.

This regulation predominantly affects Corporate Income Tax and Non-Resident Income Taxpayers with a permanent establishment, as well as Personal Income Taxpayers and entities that attribute income and engage in economic activities—excluding those who maintain VAT records through the tax administration's electronic headquarters via the Immediate Supply of Information (SII).

Who is Affected by the VERIFACTU Regulation and who needs to comply with VERIFACTU?

There are two main groups impacted by the VERIFACTU Regulation:

Producers and Marketers of Computerised Billing Systems (SIF):

These are the companies involved in the production and marketing of computer systems used for billing processes. Understandably, it is crucial to ensure that you make use of a compliant software solution. Have more questions or concerns about software developers? Reach out to us at eezi. 

Business Owners and Professionals in Spain:

These include both individuals and legal entities established in Spanish territory who issue invoices, provided they meet the following conditions:

1. Do NOT Invoice Manually: They use some form of a computerised billing system (SIF) instead of issuing invoices manually.
2. Are NOT Subscribed to SII: They are not subscribed, either mandatorily or voluntarily, to the Immediate Supply of Information (SII) system.
3. Do NOT Have Tax Domicile in Specific Territories: Their tax domicile is not in the Historical Territories of the Basque Country or the Foral Community of Navarra.
4. Do NOT Have Exemption Resolution: They do not have any active resolution exempting them from complying with the RRSIF, as approved by Royal Decree 1007/2023.

How does VERIFACTU work?

The VERIFACTU system operates by creating electronic records for each invoice issued. Once a business issues an invoice, it must submit it to the tax agency in real-time.

Here’s how the process works:

Invoice Creation
The business generates an invoice, either through its billing system or via third-party invoicing software certified by the tax authorities.

Data Submission
The invoice data, including VAT information and transaction details, is sent to the Spanish Tax Agency.

 Verification by the Tax Authorities
The tax authorities verify the accuracy of the invoice data. Any discrepancies may result in requests for adjustments or clarifications from the business.

Confirmation of Receipt
Upon successful verification, the tax agency sends a confirmation to the business, acknowledging the receipt and validity of the invoice.

Ongoing Compliance Monitoring
The Spanish Tax Agency continuously monitors the invoices submitted to ensure businesses are meeting SII requirements and complying with VAT and other tax regulations.

When Will the Regulation Become Mandatory?

Business owners and professionals who issue invoices and are affected by the regulation must ensure their computerised billing systems (SIF) meet the established requirements by 1 July 2025.

Producers and marketers of these SIFs must have their products fully compliant with the regulation within nine months after the ministerial order specifying the technical requirements comes into effect. However, for SIFs covered by multi-annual maintenance contracts signed before the deadline, they must be compliant by 1 July 2025.

If businesses adapt their SIFs earlier, they can start using them before the deadline.

The Future of mandatory e-invoicing in Spain

The concept of mandatory electronic invoicing in Spain is not new. It was first introduced in Law 56/2007, which aimed to encourage electronic invoicing among companies interacting with public administrations for improved efficiency and transparency.

Law 18/2022, known as the Crea y Crece law further mandates the use of electronic invoices for all B2B transactions. The Crea y Crece Law, introduced in September 2022, outlines the initiative to mandate electronic invoicing for all commercial transactions between businesses and self-employed individuals in Spain. The law's goal is to improve payment efficiency and oversight, reduce commercial debts, and foster business growth by exclusively using electronic invoices.

The Royal Decree will become mandatory twelve months after it is published in the Official State Gazette (BOE) and will apply to all companies and professionals. Based on the draft submitted to the European Commission, the implementation phases are as follows:

• Within 12 months from the publication date: Companies with an annual turnover exceeding €8 million must start issuing and receiving electronic invoices, along with notifying the corresponding statuses.
• Within 24 months from the publication date: Companies with an annual turnover less than €8 million must begin issuing and receiving electronic invoices.
• Within 36 months from the publication date: Companies with an annual turnover less than €8 million must start notifying the corresponding statuses.

During the first 12 months after the Royal Decree comes into effect, companies required to issue electronic invoices must also provide a PDF copy to ensure readability for recipients who are not yet obligated to receive electronic invoices, unless the recipients have explicitly agreed to receive the invoices in their original format. Learn more about e-invoicing mandates in Spain in our blogpost.

Conclusion

Adopting VERIFACTU is not only a requirement but a step towards greater operational efficiency, reduced tax fraud, and better VAT compliance. With the July 2025 deadline fast approaching, now is the time to ensure your business is fully prepared to comply with Spain’s new regulation.

If you need assistance navigating this transition, don’t hesitate to contact the eezi team. Our experts are ready to help you integrate compliant invoicing software into your business to ensure a smooth and timely transition. Stay ahead of the curve and ensure your business is ready for the future of e-invoicing in Spain.