Verifactu and mandatory B2B e-invoicing are two separate obligations that are often confused — and most businesses have to comply with both. Answer 4 questions and find out which one applies to you, the exact deadline for each, and what you need to comply, with data verified against the BOE.
Determines your Verifactu deadline — companies and self-employed people have different timelines.
The SII and the regional systems fall outside the scope of Verifactu — but not of B2B e-invoicing.
Determines your phase for B2B e-invoicing — the threshold is the same for everyone, with no territorial exception.
This obligation (B2G) is separate from Verifactu and B2B e-invoicing, and has already been in force for years.
| Verifactu | B2B e-invoicing | |
|---|---|---|
| Regulation | Royal Decree 1007/2023, amended by RD 254/2025 and extended by Royal Decree-Law 15/2025 | Law 18/2022 "Crea y Crece", developed by Royal Decree 238/2026 |
| What it regulates | The technical requirements of your invoicing software towards the Tax Agency: invoices cannot be altered or deleted | The format of invoices between businesses: electronic and structured, not a PDF |
| Objective | Tax control and combating fraud | Commercial transparency and reducing late payment between businesses |
| Who it applies to | Any business or professional that invoices, except those excluded (SII, Basque Country, Navarre) | Any business or professional in B2B transactions, with no territorial exclusion |
| Deadline | 1 Jan 2027 (companies) · 1 Jul 2027 (rest) | Estimated: 12-24 months from a ministerial order still unpublished |
| Penalty | Up to €50,000/tax year for uncertified software (art. 201 bis LGT) | Warning or fine of up to €10,000 (art. 12, Law 18/2022) |
Company or self-employed — Verifactu splits the deadlines differently depending on whether you pay Corporate Income Tax or personal income tax (IRPF).
SII, Basque Country or Navarre take you outside the scope of Verifactu — but not of B2B e-invoicing.
The €8 million threshold decides whether your B2B e-invoicing lands in phase 1 or phase 2.
The logic is local JavaScript: no answer is ever sent to a server or stored anywhere.
Verifactu and B2B e-invoicing, compared side by side, with the exact regulation and what you need to comply with each.
Verifactu and B2B e-invoicing were announced almost at the same time, share the word "invoicing" in their name, and even overlap on the calendar — but they are two different rules, with different objectives, born from different laws. That coincidence of dates is the main source of confusion we see among SMEs and self-employed people: many believe that complying with one exempts them from the other, and that isn't the case. Usually you have to comply with both, each with its own deadline and procedure.
Verifactu (Royal Decree 1007/2023, amended by RD 254/2025 and with its deadline extended by Royal Decree-Law 15/2025, of 2 December) regulates the software you use to invoice: it requires that already-issued invoices cannot be altered, deleted or reordered without leaving a trace, and offers two modes — Verifactu, which sends every invoice to the AEAT the moment it is issued, or non-Verifactu, which keeps a chained-hash record inside your own business. It is a tax-control obligation: its ultimate recipient is the Tax Agency. Companies have until 1 January 2027, and the rest of obligated parties (self-employed people under IRPF, non-residents with a permanent establishment, entities under the income-attribution regime) until 1 July 2027. Those who already use the SII are excluded, as are those with tax residence in the Basque Country (TicketBAI) or Navarre (NaTicket), equivalent regional systems managed by their own regional Treasuries.
B2B e-invoicing stems from Law 18/2022, "Crea y Crece", and its technical development arrived with Royal Decree 238/2026, of 25 March, already approved and published in the BOE on 31 March 2026. It regulates something else: the format of the invoice exchanged between two businesses or professionals, which must be electronic and structured — not a PDF attached to an email — so both parties can process it automatically. Its stated objective is not tax-related but about commercial transparency: giving visibility to real payment terms between businesses and reducing late payment. It has no territorial exclusions: it applies equally across the whole country, whether or not you use the SII.
Here is the fact worth knowing as of today: Royal Decree 238/2026 sets the application deadlines — 12 months for those who invoiced more than €8 million the previous year, 24 months for the rest, self-employed people included — but both are counted from the entry into force of a ministerial order that, as of today, has still not been published in the BOE. The Ministry of Finance put its draft order out for public consultation on 16 April 2026, and several professional sources place its expected entry into force around 1 October 2026 — which would push the deadlines to around October 2027 and October 2028 respectively. These are estimated dates, not confirmed ones: any calculator that gives you an exact day for B2B e-invoicing today is extrapolating, not quoting the BOE. Always check the status of that order at the Spanish Tax Agency's headquarters before planning around it.
There is a third piece worth not mixing up with the two above: if you invoice a public administration, e-invoicing has already been mandatory since 15 January 2015 (Law 25/2013, via the FACe entry point). This B2G obligation predates the other two, is separate, and has already been in force for over a decade — it does not depend on Verifactu or on the new B2B rule, though it is worth keeping in mind because the technical infrastructure (Facturae format, electronic signature) is similar to what is now being extended to relationships between private businesses.
If your result tells you Verifactu applies to you, our Verifactu deadline calculator has the full step-by-step checklist. All of this is part of our digitalisation area, where we also cover the Kit Digital grant and AI adoption in SMEs.
Verifactu (Royal Decree 1007/2023) sets the technical requirements your invoicing software must meet for the Spanish Tax Agency: invoices cannot be altered or deleted and, if you choose the Verifactu mode, they are sent automatically to the AEAT. B2B e-invoicing (Law 18/2022, "Crea y Crece") regulates the format of invoices exchanged between businesses: it must be electronic and structured, not a PDF, to improve transparency and reduce late payment. These are separate obligations, with different rules, deadlines and goals — most businesses will have to comply with both.
It depends on your case, but overlap is common. Verifactu applies because of the software you use to invoice, unless you already use the SII or your tax residence is in the Basque Country or Navarre. B2B e-invoicing applies because you invoice other businesses or professionals, with no territorial exclusion. You can be subject to one and not the other: for example, if you only invoice consumers you are not affected by B2B e-invoicing, and if you already use the SII, Verifactu does not apply even though you keep invoicing other businesses.
If you are a company (subject to Corporate Income Tax), before 1 January 2027. If you are self-employed, a non-resident with a permanent establishment, or an entity under the income-attribution regime, before 1 July 2027, under Royal Decree-Law 15/2025, of 2 December. You are excluded if you already use the SII, or if your tax residence is in the Basque Country (TicketBAI) or Navarre (NaTicket).
Royal Decree 238/2026, of 25 March, has already been approved and published in the BOE, but the real countdown (12 months for turnover above €8 million, 24 months for the rest) only starts once the ministerial order regulating the public e-invoicing solution enters into force — and as of today that order has still not been published in the BOE. Based on the latest forecasts from professional sources, the estimated dates would be around October 2027 and October 2028, but these are estimates, not confirmed dates: check the status of that order with the Spanish Tax Agency before treating them as final.
If you invoice a public administration, e-invoicing has already been mandatory since 15 January 2015 (Law 25/2013, via FACe). This is a separate obligation that has been in force for years, unrelated to the new B2B obligation between private businesses.
Book a free 30-minute session. We'll go through your result, clarify which obligation weighs more in your case, and what concrete steps to take first.
Book a free session →