BetaExpect changes.
SAF-T Validator
Country Updates
ES

Spain's SII, VeriFactu, and B2B E-Invoicing Mandate: Three Systems Businesses Should Know

8 min readSAF-T Validator Team

Spain is the only EU country running three separate digital tax compliance systems at once. Where most countries have one system for e-invoicing or tax reporting, Spain has three: SII for real-time invoice reporting, VeriFactu for certified invoicing software, and a mandatory B2B e-invoicing mandate under Law 18/2022. Each covers a different part of the invoicing process, and businesses may need to comply with more than one.

At a glance (March 2026)

  • SII: live since July 2017 for large taxpayers (roughly 62,000 businesses)
  • VeriFactu: January 1, 2027 for companies; July 1, 2027 for sole traders (postponed twice, most recently via Royal Decree-Law 15/2025)
  • B2B mandate: pending; 12 months after Ministerial Order publication for businesses above €8M turnover, 24 months for all others
  • SII-compliant businesses remain exempt from VeriFactu

SII: Real-Time Invoice Reporting

The SII (Immediate Supply of Information), established under Royal Decree 596/2016, is Spain’s real-time invoice data reporting system. Businesses transmit structured XML records of their invoice data directly to the AEAT (the Spanish Tax Agency) within four calendar days of issuance or receipt. This gives the tax authority continuous visibility into VAT transactions without requiring full e-invoicing.

Who must comply

  • Large taxpayers with annual turnover above €6,010,121.04
  • VAT groups operating under a single registration
  • REDEME participants enrolled in the monthly VAT refund scheme
  • Bonded warehouse holders for fuel products (since January 2025)

Voluntary opt-in is available for businesses below these thresholds. Opting in does not force monthly VAT return filing (a common misconception), and SII participants no longer need to submit models 347 or 340. Full technical specifications are published by the Spanish Tax Agency.

VeriFactu: Certified Invoicing Software

VeriFactu (Invoice Verification), introduced through Royal Decree 1007/2023, targets the broader business population not covered by SII. Where SII focuses on reporting invoice data, VeriFactu addresses the integrity of invoice generation itself, ensuring that software cannot be used to manipulate or delete records.

Technical requirements

  • Hash chains linking each invoice record to the previous one, creating a tamper-evident sequence
  • QR codes on every invoice, allowing the AEAT or recipient to verify authenticity; invoices must display the "VERI*FACTU" marking
  • 60-second transmission of invoice data to the AEAT after generation
  • SIF certification (Invoicing Computer System) guaranteeing record integrity, traceability, and immutability

The mandate has been postponed twice. Most recently, Royal Decree-Law 15/2025 (December 2025) extended deadlines to January 1, 2027 for Corporate Tax payers and July 1, 2027 for sole traders. The AEAT published a formal information note confirming this extension.

The B2B E-Invoicing Mandate (Law 18/2022)

Law 18/2022, known in Spain as the “Crea y Crece” (“Create and Grow”) law, introduces a fully separate B2B e-invoicing obligation. Once in force, all B2B transactions between businesses and self-employed professionals established in Spain must use structured electronic invoices. PDF invoices will no longer be valid.

The Ministry of Economic Affairs published a draft Ministerial Order in March 2025 for public consultation. Key decisions from that draft:

  • Formats: invoices must comply with EN 16931. Accepted syntaxes are UBL (ISO/IEC 19845:2015), CII, EDIFACT (ISO 9735), and Facturae, with UBL as the primary format for the public platform
  • Platforms: businesses can exchange through private platforms, the AEAT’s public solution, or both; private platforms must convert between all supported formats
  • Status tracking: recipients must report invoice status (acceptance, rejection, payment) within four calendar days
  • Digital signatures: eIDAS-compliant advanced electronic signatures required for authenticity and integrity

When does it start? The obligation does not begin on a fixed date. It kicks in 12 months after the Ministerial Order is published in the Official State Gazette (BOE) for businesses with turnover above €8 million, and 24 months after publication for all others. As of March 2026, the Order has not been published, so large companies are unlikely to face mandatory compliance before mid-to-late 2027, with smaller businesses following in 2028.

How the Three Systems Fit Together

In short: SII controls what data reaches the tax authority, VeriFactu controls how your software creates invoices, and the B2B mandate controlshow you exchange invoices with other businesses. Most B2B businesses will need both VeriFactu-compliant software and compliant invoice exchange under Law 18/2022. The exception is businesses already in SII, which are exempt from VeriFactu but will still need to follow the B2B e-invoicing rules once they take effect.

Practical tip: Mid-sized businesses approaching the €6,010,121.04 turnover threshold should consider voluntary SII opt-in. SII exempts them from VeriFactu entirely, and the infrastructure is mature after nearly nine years. The trade-off is committing to four-day reporting and systems integration. Even so, SII participants will still need to prepare for the B2B e-invoicing requirements when they come into force.

Timeline of Key Dates

Already in effect

  • July 2017: SII goes live under Royal Decree 596/2016
  • September 2022: Law 18/2022 (B2B e-invoicing mandate) published
  • October 2023: Royal Decree 1007/2023 introduces VeriFactu
  • January 2025: Bonded warehouse holders added to SII scope
  • March 2025: Draft Ministerial Order for the B2B mandate opens for consultation
  • December 2025: Royal Decree-Law 15/2025 postpones VeriFactu
  • January 2026: Council of State Opinion No. 1203/2025 advances the B2B mandate

Coming next

  • January 1, 2027: VeriFactu mandatory for Corporate Tax payers
  • July 1, 2027: VeriFactu extends to sole traders
  • 2027/2028 (est.): B2B e-invoicing goes live, phased by turnover
  • 2030: EU ViDA real-time digital reporting target

Penalties

  • VeriFactu (users): up to €50,000/year for using non-compliant invoicing software
  • VeriFactu (vendors): up to €150,000/year per product type for selling non-compliant software
  • B2B mandate: up to €10,000 for failing to issue electronic invoices
  • Invoice errors: 1 to 2% of transaction value, rising to 75% in cases of fraud

Spain and EU ViDA

Spain has not adopted the OECD SAF-T standard. SII serves a similar purpose, providing structured near-real-time transaction data to the tax authority. This puts Spain on a different path from countries like France or Hungary, which pair e-invoicing with SAF-T or RTIR systems.

With the EU ViDA (VAT in the Digital Age) initiative targeting real-time digital reporting by 2030, SII is widely regarded as Spain’s foundation for ViDA compliance. Nearly nine years of operational experience put Spain well ahead of member states still building their reporting infrastructure. VeriFactu and the B2B mandate add software integrity and structured invoice exchange on top of the existing reporting layer. For a comparative view across the continent, see our SAF-T adoption across Europe overview.

Why three systems? Because large taxpayers needed real-time reporting controls years before anti-fraud and e-invoicing rules could be rolled out to millions of smaller businesses. Whether VeriFactu’s 2027 deadlines hold after two postponements remains to be seen, and the B2B e-invoicing timeline depends on when the Ministerial Order is published. Either way, all businesses should be getting their systems ready.

Ready to Validate Your FAIA Files?

Try our privacy-first Luxembourg FAIA validator. Client-side validation ensures your financial data never leaves your browser.