VeriFactu and Spain's B2B e-invoicing law: what each one requires and when

Short answer: Spain has two separate reforms. VeriFactu sets rules for the software that issues invoices: from 1 January 2027 for companies and 1 July 2027 for everyone else, under current law, although the Ministry of Finance announced on 5 October 2026 that it plans to move this to October 2028. The B2B e-invoicing obligation under Royal Decree 238/2026 requires structured e-invoices between businesses from 6 October 2027 for turnover above €8 million and 6 October 2028 for everyone else. A business can be caught by one, both or neither.

This article is an overview, not tax advice. It reflects the BOE texts and Agencia Tributaria guidance available on 26 October 2026.

The two reforms side by side

VeriFactu: what the software must do

VeriFactu is about integrity of invoicing records, not about sending invoices in a new format. Software used to issue invoices must produce a billing record for each invoice, chained to the previous one with a hash and protected against later changes. It can work in two ways:

• VERI*FACTU mode: the software sends each record to the Agencia Tributaria, and the invoice carries a QR code and the "VERI*FACTU" mention.
• Non-verifiable mode: records stay in the software but must still meet the regulation's requirements on hashing, signatures and record keeping.

The Agencia Tributaria's FAQ lists four conditions, all of which must apply, for a business to be in scope. The business:

1. does not invoice only by hand,
2. is not on the SII (Suministro Inmediato de Información), mandatorily or voluntarily,
3. does not have its tax domicile in the Basque Country or Navarre,
4. has no resolution in force exempting it.

Dates in force today. Royal Decree-law 15/2025, published in the BOE on 3 December 2025, set the deadlines at before 1 January 2027 for corporate income taxpayers and before 1 July 2027 for everyone else, such as self-employed professionals. Software producers had to offer compliant products from 29 July 2025.

The October 2028 announcement. On 5 October 2026 the Ministry of Finance published a note saying it plans to defer the pending VeriFactu obligations to October 2028, to line them up with the B2B e-invoicing date for businesses with turnover up to €8 million. The note is a forecast. It says a further amendment will follow once the calendars are aligned, aiming to bring the two systems closer technically and to allow for the EU's future digital reporting rules (see ViDA 2030 for accounting firms). It does not name the legal instrument. If you searched for "BOE VeriFactu 2028": as of 26 October 2026 we could not find that amendment published in the BOE, and the Agencia Tributaria's FAQ still gives the 2027 dates. Plan for 2027 and treat 2028 as likely, not certain.

B2B e-invoicing: what Royal Decree 238/2026 requires

Royal Decree 238/2026 of 25 March, published on 31 March 2026, sets up the system. Order HAC/1028/2026 of 2 October, published in the BOE on 5 October 2026, defines the public solution, and its entry into force on 6 October 2026 started the clock.

Dates, as given by the Agencia Tributaria:

Scope. The obligation applies when the recipient is a business or professional with its seat, a permanent establishment or, failing those, its domicile in Spain. Simplified invoices are excluded, as are some regulated energy and IATA settlements.

Format. The invoice must follow the EN 16931 semantic model in one of four syntaxes: UBL, CII, EDIFACT or Facturae. Invoices through private platforms need an advanced electronic signature.

Channels. Businesses can use the public solution run by the Agencia Tributaria, which is free, or a private platform. Private platforms must interconnect with each other within a month of a request, at no charge, and must send a UBL copy of each invoice to the public solution. A recipient that has not agreed to a private platform is treated as using the public solution.

Status reporting. The recipient must report commercial acceptance or rejection and the date of full payment, within four calendar days of the event, not counting weekends and national holidays. This is how Spain plans to monitor late payment.

SII taxpayers are outside VeriFactu, but nothing in Royal Decree 238/2026 exempts them from B2B e-invoicing. A large SII company will need both SII reporting and e-invoicing from 6 October 2027.

Basque Country and Navarre. Foral taxpayers stay outside VeriFactu; Basque businesses use TicketBAI. For B2B e-invoicing, the decree says the public solution for foral taxpayers will follow the Basque Concierto Económico and Navarre's Convenio Económico, through agreements between the foral tax authorities and the Agencia Tributaria. The decree does not exclude foral taxpayers from the obligation; the practical arrangements are still to be agreed.

What a foreign supplier or accountant needs to know

• VeriFactu covers non-resident businesses only where they have a permanent establishment in Spain, according to the Agencia Tributaria's FAQ.
• B2B e-invoicing is defined by where the recipient is. The decree applies to businesses already required to issue invoices under Spain's invoicing regulation and does not separately address suppliers that are not established in Spain. If a client invoices Spanish customers from abroad, get a Spanish adviser's view before 2027.
• Your Spanish clients' customers will ask. Expect requests for a Peppol or platform address, or for invoices in UBL, from Spanish buyers preparing for 2027.

For a summary of Spanish VAT and invoicing, see our Spain country guide.

What changes for incoming invoices

For a bookkeeper processing purchases for a Spanish client, the changes come in this order:

1. 2027: invoices from suppliers whose software runs in VERI*FACTU mode carry a QR code. Nothing changes in how you book them.
2. From 6 October 2027: large suppliers send structured e-invoices. For the first 12 months, the decree requires them to attach a PDF for readability unless the recipient accepts the original format only. The structured file is the invoice; the PDF is a copy.
3. Status deadlines: a client with turnover above €8 million must report acceptance or rejection, and payment, within four working days. A supplier invoice of €1,742.80 approved on Friday and paid on Monday creates two reports, so approval and payment need to be recorded promptly, not at month-end.
4. From 6 October 2028: all Spanish suppliers send e-invoices, and smaller companies take on status reporting too.

Foreign suppliers, simplified invoices and receipts will still arrive as PDFs and paper. Dates for other countries are in our e-invoicing deadlines tracker.

Where Invoreg fits

Invoreg works on the purchase side. It reads supplier invoices in any format that arrives, including Peppol UBL and other XML e-invoices, PDFs, scans and phone photos, reads every line with its VAT rate, suggests the coding from the client's history and registers the bill in the accounting software once a person approves it. Purchase approvals and the audit log record who approved what and when.

Invoreg is about incoming supplier invoices. Clients still need VeriFactu-compliant software for the invoices they issue, and the public solution or a private platform for sending and receiving e-invoices. To see it on a mix of Spanish supplier invoices, try it on your own invoices: the first 20 invoices are free.