Spain is implementing one of Europe's most comprehensive mandatory electronic invoicing systems. Unlike some EU countries where e-invoice obligations apply only to government contracts, Spain's Ley Crea y Crece (Ley 18/2022) extends the obligation to all B2B commercial relationships — affecting millions of companies and self-employed workers who currently issue invoices in PDF or paper format.
The two legislative layers
Understanding Spain’s e-invoice framework requires distinguishing between two instruments that operate together:
Ley 18/2022 (Ley Crea y Crece) — the commercial obligation
Art. 12 of Ley 18/2022 amends the Ley de Medidas de Impulso de la Sociedad de la Información to require all empresarios y profesionales (companies and self-employed workers) to issue, transmit and receive electronic invoices in their commercial relationships with other empresarios y profesionales. This creates a bilateral obligation: not only must you issue e-invoices to your business clients, but you must also be capable of receiving and processing e-invoices from your suppliers.
RD 1007/2023 — the technical standards (Verifactu)
Real Decreto 1007/2023 specifies how billing software must work to generate compliant invoices. The core requirement is the registro de facturación (invoice registration record): billing software must create a hash-linked chain of all invoices issued, where each invoice record includes a cryptographic reference to the previous one. This makes the invoice sequence tamper-evident — any deletion or alteration of an invoice breaks the chain, providing the AEAT with a technical audit mechanism.
Deadlines: who must comply and by when
| Company profile | Compliance deadline |
|---|---|
| Annual turnover > €8 million (companies and self-employed) | July 2025 (12 months from ministerial order) |
| All other companies and self-employed workers | July 2026 (24 months from ministerial order) |
| B2G transactions (public administrations) | Already subject to FACe/FACE system — separate obligation |
The ministerial order establishing technical specifications was expected in Q1–Q2 2025. The countdown runs from the order’s publication date, so the precise dates will be confirmed once the order is published. The July 2025 / July 2026 estimates are the government’s stated timeline.
Technical requirements for a compliant e-invoice
A PDF sent by email is not a compliant electronic invoice under these regulations. The requirements:
1. Structured XML format
The invoice must be in a machine-readable XML format. Spain uses two compatible standards:
- Facturae 3.2.x (Spanish national standard, specifically for Spanish fiscal requirements)
- UBL 2.1 (Universal Business Language, EU standard)
Both formats allow all required invoice fields to be present in structured, parseable form. This is what allows both sender’s and recipient’s accounting systems to process the invoice automatically.
2. QR code
Each invoice must include a QR code encoding the essential invoice identification data. This allows any party (including the AEAT) to verify the invoice quickly by scanning the code.
3. Electronic signature
The invoice must carry a qualified electronic signature from the issuer, generated using a qualified certificate issued by a trusted Certification Authority (e.g., FNMT — Spain’s national mint and stamp factory). This ensures authenticity and non-repudiation.
4. Verifactu registration record
The billing software must generate a hash-chain registration record (registro de facturación): a cryptographic fingerprint of each invoice that references the prior invoice’s fingerprint, creating a tamper-evident chain. The AEAT may request submission of these records in real time (voluntarily) or during an inspection.
Optional vs mandatory AEAT submission
Under RD 1007/2023, companies can choose between two modes:
Verifactu mode (voluntary real-time submission): the billing software sends each invoice’s registration record to the AEAT in real time via the Verifactu API. In exchange, the AEAT confirms receipt and the invoice carries the AEAT’s verification mark. This mode provides a strong compliance signal and reduces inspection risk.
Non-Verifactu compliant mode: the software maintains the hash-chain records internally but does not submit them to the AEAT in real time. The AEAT can still request them during an inspection. This mode meets the minimum legal requirement but provides less protection against fraud accusations.
Most compliance advisers recommend the voluntary real-time Verifactu submission mode — the operational overhead is minimal and the protection is greater.
Verifactu vs SII: clarifying the confusion
These two systems are frequently confused:
| Feature | SII | Verifactu |
|---|---|---|
| Who it applies to | Large companies (turnover > €6M), VAT groups, monthly VAT filers | All companies and self-employed (phased by size) |
| What is submitted | VAT ledger data (invoices issued and received) | Invoice registration records (hash-chain) |
| Timing | Within 4 days of invoice date | Real-time (optional) or on inspection request |
| Purpose | VAT reporting | Billing software audit trail |
| Entry into force | 2017 | 2025/2026 (phased) |
If your company is already on the SII, Verifactu is a different additional requirement concerning your billing software’s internal record structure — not a duplicate of the SII data submission.
Implementation steps: a practical checklist
6–12 months before your deadline:
- Audit your current billing software: can it generate Facturae XML? Does it have a Verifactu certification (or confirmed roadmap)?
- Contact your software provider for their Verifactu compliance timeline and certification status
- Assess whether your current system needs upgrade or replacement
- Check your qualified electronic certificate (certificado electrónico de representante) — if it expires before the deadline, renew it
3–6 months before:
- Select Verifactu-compliant software if switching is required
- Plan data migration from old system
- Train finance and invoicing staff on the new process
- Test XML output against the Facturae validation schema (the Facturae consortium provides a free validator)
- Confirm that your main customers’ systems can receive and process Facturae XML
1 month before:
- Run parallel operation: issue invoices in both old and new format, compare outputs
- Verify QR codes scan correctly and link to verifiable data
- Confirm electronic signature is valid and the certificate is correctly installed
- Complete switch to compliant system before the deadline date
Ongoing:
- Monitor AEAT announcements for any changes to the Verifactu technical specifications
- Ensure your billing software provider releases updates promptly when the AEAT issues updated specifications
Common compliance mistakes
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Believing PDF invoices already comply. They do not — even PDFs with digital signatures. The requirement is structured XML data, not a visually presented document.
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Confusing e-invoice with e-delivery. A compliant e-invoice can be delivered by any channel (email, API, portal), but the format must be XML, not PDF.
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Ignoring the receiving side. You must also be able to receive e-invoices from suppliers. If your accounting system cannot process Facturae XML input, you are non-compliant even if you issue correctly.
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Assuming the obligation only applies from the deadline. Contracts with public bodies (B2G) have had e-invoice requirements since 2015. The new rules extend this to B2B.
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Waiting until the deadline to start. Software migrations, staff training and technical integration with customers typically take 3–6 months. Starting at the deadline means non-compliance for the first months of the obligation.
How BMC can help
Our electronic invoicing service covers the full implementation journey: compliance assessment, software selection guidance, technical implementation support, staff training, and ongoing compliance monitoring. We work with clients across all sectors and company sizes, from single-person autónomos to mid-size SMEs.
If you are not sure whether your current billing system will meet the new requirements, contact us for an initial assessment. Starting early is the single most effective risk reduction strategy.
