Tax · Invoicing 2027

Spain e-invoicing and Verifactu: are you obligated and when?

Two separate obligations that get confused. Check your dates: Verifactu (billing software) and B2B e-invoicing under the Crea y Crece Law. Verified dates (RD-ley 15/2025 and RD 238/2026).

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Determines the B2B e-invoicing deadline

Verifactu (billing software)

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B2B e-invoicing (Crea y Crece)

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Verifactu, billing software and e-invoicing · No obligation

Indicative result based on the rules in force at the review date. The specific obligations and their exceptions depend on the activity and possible extensions. To adapt your systems, consult our advisers.

Verifactu timeline

Verifactu obligation dates by taxpayer type
Obligated party Required from
Corporate income tax payers 1 January 2027
Self-employed (IRPF), income attribution and non-residents with PE 1 July 2027
Taxpayers enrolled in the SII Exempt from Verifactu

B2B e-invoicing timeline

B2B e-invoicing obligation dates by turnover
Obligated party Required from
Companies with turnover above €8M October 2027
SMEs and self-employed with turnover below €8M October 2028

Sources: RD 1007/2023 (Verifactu) · RD 238/2026 (B2B e-invoicing) · Ley 18/2022 (Crea y Crece) · RD-ley 15/2025 (Verifactu postponement)

Verifactu is not the same as B2B e-invoicing

The most common confusion is treating Verifactu and B2B e-invoicing as the same obligation. They are two different things that coexist:

  • Verifactu (RD 1007/2023) governs the billing software: how it must generate records (immutable, chained with a hash) and the QR code on each invoice. It is a relationship between issuer and tax authority. It affects almost all SMEs and self-employed under direct estimation, except those enrolled in the SII.
  • B2B e-invoicing (Crea y Crece Law, RD 238/2026) governs the document format and its exchange between businesses and professionals: it requires issuing and receiving invoices in a structured format (Facturae) and reporting their status. It is a relationship between issuer and recipient, with the added aim of fighting commercial late payment.

In practice, most companies will have to meet both: software compliant with Verifactu that also issues and receives structured electronic invoices once its B2B deadline arrives. Planning the adaptation ahead of time avoids last-minute rushes and penalties.

A BMC client advantage

Don't buy software: issue compliant invoices from your platform

Adapting to Verifactu and e-invoicing does not have to mean buying and configuring software. The BMC platform includes, at no extra cost for our clients, a tool to issue your invoices: records compliant with Verifactu (immutable and with a QR code) and in structured electronic format (Facturae), with the series and numbering the rule requires. You comply from day one, with your tax advisory built into the same place.

Verifactu-compliant

Immutable, chained record with a QR code verifiable at the tax authority.

Facturae format

Structured electronic invoice, ready for the B2B mandate.

No extra cost

Included for BMC clients. No external licences to buy.

Frequently asked questions

What is the difference between Verifactu and mandatory e-invoicing?
They are two separate obligations that are often confused. Verifactu (RD 1007/2023) governs how billing software must behave: it requires programs to generate immutable records (chained with a hash) and to include a QR code on the invoice; it is a relationship between the issuer and the tax authority. B2B e-invoicing (Ley 18/2022, Crea y Crece, developed by RD 238/2026) requires businesses and professionals to issue and receive invoices in a structured electronic format (Facturae); it is a relationship between issuer and recipient. One governs the software; the other governs the document format and its exchange.
When does Verifactu become mandatory?
RD-ley 15/2025, of 2 December, postponed the original dates by a year. The current dates are: 1 January 2027 for corporate income tax payers, and 1 July 2027 for self-employed under IRPF, income attribution entities and non-residents with a permanent establishment. Software developers had to adapt their systems before those dates. Taxpayers enrolled in the Immediate Supply of Information (SII) are exempt from Verifactu, because they already report their record books to the tax authority in near real time.
When does B2B e-invoicing become mandatory?
Royal Decree 238/2026, of 25 March, developed the mandatory B2B e-invoicing set out in the Crea y Crece Law. The deadlines are staggered by turnover: companies with turnover above €8 million are required from October 2027 (one year after the technical order), and SMEs and self-employed professionals below €8 million from October 2028 (twenty-four months). In addition, all obligors must report the status of each invoice (accepted, rejected or paid) within a maximum of four business days.
Am I obligated if I already file the SII?
If you are enrolled in the Immediate Supply of Information (SII) for VAT, you fall outside Verifactu's scope: you do not need Verifactu software because you already submit your billing records to the tax authority in near real time. However, the B2B e-invoicing obligation of the Crea y Crece Law does apply to you regardless of the SII, depending on your turnover and the deadlines above, since it is a separate obligation covering the format and exchange of invoices.
What technical requirements does Verifactu impose?
Compliant billing software must generate, for each invoice, an immutable billing record chained to the previous one via a hash, and include a QR code that lets the recipient verify the invoice on the tax authority website. There are two modes: Verifactu mode, in which the record is sent automatically to the tax authority at the moment of issuance, and non-Verifactu mode, in which the record is kept electronically signed and available to the administration. In-house software must also meet these requirements.
How are B2B electronic invoices exchanged?
RD 238/2026 sets two interoperable exchange channels: private e-invoice exchange platforms, which must be interconnected to guarantee free interoperability, and a free public solution from the tax authority, accessible to any business or professional. The format is structured (Facturae and those admitted by the rule). Both issuer and recipient must communicate the invoice status (acceptance, rejection or effective payment) to give traceability to the transaction and to commercial late payment.

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Methodology and sources

This checker applies the rules in force on Verifactu (RD 1007/2023, with the dates set by RD-ley 15/2025) and on B2B e-invoicing (Ley 18/2022 Crea y Crece, developed by RD 238/2026) to determine, based on your profile, whether you are obligated and from which date.

Assumptions applied by this calculator

Two independent obligations
Verifactu (billing-software requirements) and B2B e-invoicing (format and exchange) are separate obligations with their own timelines. The checker evaluates them separately.
Verifactu exemption via SII
Taxpayers enrolled in the Immediate Supply of Information fall outside Verifactu, because they already submit their billing records to the tax authority. The checker applies this exemption when the SII box is ticked.
B2B deadlines by turnover
RD 238/2026 sets staggered deadlines: October 2027 for companies with turnover above €8 million and October 2028 for SMEs and self-employed below that threshold.
Subject to extensions
The Verifactu calendar has already been postponed once (RD-ley 15/2025). Dates may change through future rules; always verify they are in force before making decisions.

Official sources

Last reviewed: 2026-07-05

Reviewed by: Bárbara Botía — Of Counsel · ICAM member 11,233

This calculator provides an estimate for informational purposes. It does not replace professional advice. Results may vary based on personal circumstances and regulatory changes. Consult an advisor for personalized planning.

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