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Spain has taken two important steps in the development of its digital invoicing framework. On the one hand, the Ministry of Finance has announced plans to postpone the outstanding obligations under the invoicing software rules commonly associated with VERI*FACTU until October 2028. On the other, Spain has now completed a major part of the regulatory framework for mandatory B2B e-Invoicing, starting the countdown towards the first implementation phase in October 2027.
Although the two regimes are closely connected, they are not the same. VERI*FACTU forms part of Spain’s rules governing invoicing software and the integrity of invoice records. The new B2B e-Invoicing regime governs how businesses will issue, exchange and receive structured electronic invoices, as well as how invoice statuses and payments will be communicated.
For businesses operating in Spain, understanding how these initiatives fit together is becoming increasingly important.
On 5 October 2026, the Spanish Ministry of Finance announced its intention to postpone the outstanding obligations for businesses and professionals under Royal Decree 1007/2023 until October 2028.
The reason given by the Ministry is significant. Rather than implementing the invoicing software obligations independently, the Government wants to align them as closely as possible with the timetable for mandatory B2B e-Invoicing, particularly for SMEs and self-employed professionals. The Ministry has therefore indicated that the outstanding application dates under Royal Decree 1007/2023 should move to October 2028, coinciding with the e-Invoicing obligation for businesses and professionals whose annual turnover does not exceed €8 million.
This does not mean that the principles behind VERI*FACTU are being abandoned. The Ministry has specifically confirmed that the existing requirements relating to the integrity, preservation, accessibility, legibility, traceability and immutability of invoicing records will remain in substantially equivalent form. A further amendment is expected to address greater convergence between the scope and technical requirements of the invoicing software rules and the e-Invoicing system, while also considering the future digital reporting requirements arising from the EU’s VAT in the Digital Age, or ViDA, reforms.
There is, however, an important distinction between an announcement and a legislative amendment. The Ministry’s document describes the October 2028 change as a planned modification of the application deadlines. The relevant legislation will therefore still need to be formally amended. Businesses should not interpret the announcement as the cancellation of the SIF or VERI*FACTU regime.
While VERI*FACTU is moving later, Spain’s B2B e-Invoicing programme is moving forward.
Royal Decree 238/2026, published in March 2026, established the architecture of Spain’s mandatory B2B e-Invoicing system. This was followed on 5 October 2026 by the publication of Order HAC/1028/2026, which regulates the technical and functional operation of the Public Electronic Invoicing Solution.
The Order entered into force on 6 October 2026. This date is particularly important because it starts the statutory implementation timetable. Businesses and professionals whose volume of operations exceeded €8 million in the immediately preceding calendar year become subject to the regime 12 months later. The first phase will therefore apply from 6 October 2027. The remaining businesses and professionals will follow 24 months after the Order entered into force, from 6 October 2028.
The public solution itself must be available to affected businesses at least two months before the first effective application of the regime.
The new regime is aimed at invoices exchanged between businesses and professionals.
Under Royal Decree 238/2026, an electronic invoice is required where a business or professional is required to issue an invoice and the recipient is a business or professional whose economic activity is headquartered in Spain, has a permanent establishment in Spain or, where applicable, has its domicile or habitual residence in Spain, provided the transaction is addressed to that Spanish establishment, domicile or residence. The rules also extend to self-billing and third-party invoicing arrangements, although the party legally responsible for issuing the invoice remains responsible for compliance.
Certain simplified invoices are excluded, although qualified simplified invoices are not covered by that general exclusion.
This is therefore not simply a requirement to convert an existing PDF invoice into another electronic file. The legal invoice itself must be issued, transmitted and received as structured electronic data in accordance with the Spanish framework.
One of the most important features of the Spanish regime is that it is not based exclusively on one government platform.
Instead, Spain is introducing a hybrid system consisting of compliant private electronic invoicing platforms together with the Public Electronic Invoicing Solution managed by the Spanish Tax Agency, the AEAT. Businesses will be able to use a private provider, use the public solution, or combine the two.
The public solution has two roles. It will provide an invoicing option in its own right, particularly important for businesses that do not wish to contract with a private platform, but it will also serve as the universal repository for invoices falling under the regime. The AEAT will additionally provide a free invoice generation facility through the public solution.
This creates an important distinction between invoice exchange and invoice availability to the public solution.
A business may, for example, issue its invoice through its chosen private e-Invoicing provider and deliver it to the customer through that private network. However, where the public solution is not being used for issuance or interconnection, the invoicing system or platform must simultaneously send a faithful electronic copy of the invoice in UBL format to the public solution.
The publication of Order HAC/1028/2026 on 5 October 2026 has started the clock. Businesses with operations exceeding €8 million have until October 2027 to be ready to issue and receive compliant electronic invoices. Smaller businesses and professionals have until October 2028, though the alignment with VERI*FACTU makes early preparation sensible for both groups.
The practical steps are familiar: assess whether the regime applies to your Spanish operations, review your current invoicing systems, determine whether you will use a private e-Invoicing provider or the public solution, and confirm that your chosen approach can meet both the exchange and reporting requirements of the new framework.
eezi by VAT IT supports businesses navigating e-Invoicing mandates across 60+ countries, including Spain. Whether you are assessing your obligations or planning your implementation, our team can help you get compliant before the deadline.
Get in touch with our team to discuss your Spain e-Invoicing position.
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