Mandatory E-Invoicing in Spain: Get Your Business Compliant with Verifactu

Electronic invoicing (facturación electrónica) in Spain is the obligation to issue and transmit invoices in a structured digital format for all B2B transactions between businesses and professionals with a tax domicile in Spain, introduced by Law 18/2022 (Ley Crea y Crece) and technically specified by Royal Decree 1007/2023. The regulation establishes two compliance paths: the Verifactu system, which transmits invoice records to the AEAT (Spanish Tax Agency) in real time with a cryptographic verification code, and the SIF (Invoicing Information System), which retains records internally for on-request inspection. Non-compliance carries penalties of up to EUR 10,000 per infringement, and invoices that fail to meet required formats may be rejected by recipients, preventing input VAT deduction.

Electronic invoicing is moving from an option to a legal obligation with specific dates and real penalties. Law 18/2022 (Ley Crea y Crece) and Royal Decree 1007/2023 establish the regulatory framework; what your business needs is to understand exactly what applies to it, within what timeframe, and what technical and operational changes are required to comply without disrupting normal operations.

The regulatory framework: Ley Crea y Crece and the Verifactu system

Law 18/2022, on the creation and growth of companies, introduced in its Article 12 the obligation to issue and transmit electronic invoices in all transactions between businesses and professionals (B2B) with tax domicile in Spain. This obligation, pending regulatory development, was specified by Royal Decree 1007/2023, which establishes the technical requirements for the Verifactu system and the Invoicing Information System (SIF).

The Verifactu system is the control mechanism developed by the AEAT: businesses adopting it must use software that generates a secure verification code (CSV) on each invoice, cryptographically chains the invoicing records, and transmits the information to the AEAT in real time or near-real time. The SIF is the alternative for those who prefer to retain records internally and make them available to the AEAT only on request. Both options are valid; the choice has operational and tax authority relationship implications.

What your business needs to do before the deadline

Adapting to electronic invoicing is not purely a technology problem, even though technology is the starting point. It is a process that affects invoicing operations, internal approval workflows, relationships with clients and suppliers, and accounting systems. Companies that address it late find that their software provider does not yet have the update ready, that their clients are already demanding the new format, or that the migration of historical data generates unforeseen problems.

The first step is to understand whether your company is obligated, within what timeframe, and under which technical modality. The second is to audit the current software: is your ERP or invoicing programme on an approved Verifactu development roadmap? Is the update available or does it require migration? The third is to design the implementation plan with sufficient margin for testing and team training before the deadline.

B2G electronic invoicing: the obligation that already exists

If your company invoices public bodies (central government, regional governments, local authorities, or public sector entities), the obligation to invoice electronically has existed since 2015 under Law 25/2013 on the promotion of electronic invoicing and creation of the accounting invoice register in the public sector. Invoices must be transmitted through FACe (the General Entry Point for Electronic Invoices for the Central State Administration) or the corresponding regional platform, in FacturaE format (XML to standard). This obligation is independent and pre-dates the new B2B obligation under Ley Crea y Crece; complying with B2G does not exempt you from the new B2B obligation.

VAT and fiscal implications

Electronic invoicing has a direct impact on VAT compliance. An invoice that does not meet the required formal requirements has no validity for input VAT deduction purposes for the recipient, which can generate significant tax contingencies. The AEAT may deny input VAT deduction for received invoices that do not comply with the mandatory format, directly affecting the recipient’s cash flow. This shared responsibility — issuer and recipient — makes adaptation a bilateral interest in every business relationship.

Electronic invoicing implementation is typically coordinated with the outsourced accounting service to ensure consistency of the accounting flow, and with the process automation team when the business wants to use the change as an opportunity to digitalise the complete invoicing cycle (issuance, approval, bookkeeping and archiving). For businesses with complex tax compliance obligations, the adaptation is integrated into the annual tax planning process.