Verifactu and B2B e-invoicing: Spain's two separate deadlines

From 1 January 2027 a Spanish sociedad limitada has to issue invoices with software that signs every record, chains it to the previous one and prints a QR code on the document. That is the Verifactu regulation. On a separate clock, the same company will also have to send its invoices to other businesses as a structured file that the recipient's computer can read on its own. That is B2B electronic invoicing.

Two reforms, two rules, two purposes, two sets of dates. Anyone arriving from Italy, where the Sistema di Interscambio settled both questions at once back in 2019, goes looking for the Spanish equivalent and finds nothing: Spain split the reform into two parts that move independently.

Verifactu governs the software, not the invoice

Real Decreto 1007/2023, of 5 December, approved the RRSIF, the regulation on requirements for invoicing software. The technical specifications followed in Orden HAC/1177/2024, of 17 October, in force since 29 October that year.

What the rule governs is how the program behaves. Every invoice issued creates a registro de facturación de alta carrying a digital fingerprint (hash), electronically signed and chained to the record before it. Cancelling or correcting an invoice leaves its own trace. Rewriting the chain backwards, which is exactly what the software de doble uso targeted by the reform allowed, shows up.

There are two ways to comply:

• VERI*FACTU mode. The system sends each record to the Agencia Tributaria at the moment the invoice is issued. In exchange it is released from keeping the event log, and the invoice can be checked on the tax agency's portal.
• Non verifiable system. Records stay inside your program, signed and preserved, alongside an event log documenting every system incident. The Agencia will ask for them if it opens an audit.

Either way, the invoice carries a QR code.

Who is covered, and from when

Article 3 of the regulation draws the perimeter: corporate income tax payers, personal income tax payers carrying on an economic activity, non-resident income tax payers operating through a permanent establishment, and income-attribution entities with an economic activity.

Left outside are those who keep their VAT ledgers through the tax agency's portal, meaning anyone inside the Suministro Inmediato de Información (SII). Also outside are the Basque Country and Navarra, where TicketBAI and its regional equivalents apply. And outside is anyone who invoices by hand, with no software involved.

The dates have moved twice. Most recently through Real Decreto-ley 15/2025, of 2 December, published in the BOE on 3 December and approved by Congress on the 11th:

• 1 January 2027 for corporate income tax payers. That covers your SL or SA.
• 1 July 2027 for everyone else obliged. That covers the self-employed, and also the Spanish branch of an Italian company, which pays non-resident income tax.

The distinction is worth six months. If your Italian group operates in Spain through a filial, the date is January; through a sucursal, July.

One detail slips past most people: the delay applied to those who issue invoices, not to those who sell the software. Producers and distributors have been bound since 29 July 2025, nine months after the technical order took effect, to offer compliant systems backed by a responsibility statement. If you bought a program after that date and nobody has shown you that statement, the problem starts well before 2027.

Penalties sit in article 201 bis of the Ley General Tributaria: up to 50,000 euros per financial year for holding non-compliant systems, and up to 150,000 euros per year and per type of system for producing or selling them.

B2B electronic invoicing runs in a different lane

The duty to invoice electronically between businesses and professionals comes from Ley 18/2022 on business creation and growth, known as the Ley Crea y Crece. Its implementing regulation took three years: Real Decreto 238/2026, of 25 March, published in the BOE on 31 March and in force since 20 April 2026.

Here the rule really does govern the invoice. A structured, machine-readable file, exchanged between interoperable private platforms or through a free public solution run by the Agencia Tributaria.

The regulation adds a duty that does not exist in this shape in Italy: reporting invoice statuses. The recipient reports acceptance or rejection with its date, and full effective payment with its own, within the following four working days. The law's stated target is late payment, making the real payment terms between companies visible.

The calendar is not settled. The decree sets no dates of its own: the clock starts when the ministerial order developing the public solution takes effect. Twelve months for anyone who invoiced more than 8 million euros the previous year, twenty-four months for the rest. The draft order went out for public consultation on 17 April 2026 and foresees entry into force on 1 October 2026. If that date holds, the obligation begins on 1 October 2027 above 8 million and on 1 October 2028 for everyone else. While the order remains a draft, neither date is published in the BOE.

The Italian side, so the work is not done twice

In Italy, electronic invoicing through the Sistema di Interscambio has been compulsory since 1 January 2019, and has covered every partita IVA since 1 January 2024, when the forfettari below 25,000 euros joined.

Cross-border transactions travel the same channel since 1 July 2022, through document types TD17, TD18 and TD19, which replaced the esterometro. Worth keeping in mind if you invoice an Italian client from Spain: your Spanish invoice does not enter the SdI by itself. Your client files it there, and will ask you for the data in whatever format their commercialista needs.

What you can check this week

• If you are in the SII, the RRSIF does not apply to you. Confirm it before changing software.
• Ask your provider for the invoicing system's responsibility statement, in writing.
• Choose your mode. Sending records to the Agencia spares you the event log; the non verifiable system keeps the data at home along with the duty to preserve it.
• Look at last year's turnover: 8 million euros separates two different calendars on the B2B invoice.
• If what you have in Spain is a branch rather than a subsidiary, your Verifactu date is July 2027.

If you have any doubts, Riondato & Partners is here to help

We have spent over 45 years working between Italy and Spain, with companies that invoice in both countries and have to satisfy two sets of rules that look nothing alike. If you are staring at your company's calendar and cannot tell which date applies to you, write to us: we will go through it with you before you change software or provider.

Sources

• Real Decreto 1007/2023, requirements for invoicing software systems, BOE
• Orden HAC/1177/2024, technical, functional and content specifications, BOE
• Real Decreto-ley 15/2025, of 2 December, extending the adaptation deadlines, BOE
• Agencia Tributaria information note on the extended adaptation deadline
• AEAT frequently asked questions on the scope of VERI*FACTU
• Real Decreto 238/2026, of 25 March, mandatory B2B electronic invoicing, BOE
• Guide to filling in electronic invoices and the esterometro, Agenzia delle Entrate