Spain E-Invoicing Requirements: SII, Verifactu, Crea y Crece

Spain has four digital invoicing systems: SII (live since 2017 for large companies), Verifactu (mandatory January 2027 for corporations, July 2027 for self-employed), Crea y Crece (B2B e-invoice exchange expected 2027-2028), and TicketBAI (Basque Country regional system, already live). SII users are exempt from Verifactu, and Basque taxpayers use TicketBAI instead of Verifactu.

This guide covers each of Spain's e-invoicing requirements in detail: a decision matrix for determining which systems apply to your business, how SII, Verifactu, Crea y Crece, and TicketBAI each work, the current compliance timeline and penalties after the 2025 postponement, and how these mandates affect businesses receiving invoices from Spanish suppliers.

Which of Spain's E-Invoicing Systems Applies to Your Business?

Spain does not have a single e-invoicing mandate. It has four distinct systems, each targeting different taxpayer segments, transaction types, and compliance objectives. A fifth, FACe, has governed public sector invoicing since 2015. Understanding which systems apply to your organization requires mapping your business profile against each mandate's scope.

The following decision matrix provides that mapping at a glance.

System	Status	Who It Applies To	What It Requires
FACe (B2G)	Live since January 15, 2015	All suppliers invoicing Spanish public sector entities (invoices over 5,000 EUR)	Facturae XML format with XAdES electronic signature, submitted through the FACe portal
SII	Live since July 1, 2017	Companies with annual turnover above 6,010,121.04 EUR, REDEME (Monthly Refund Register) members, VAT groups, and voluntary opt-ins	Near-real-time submission of invoice data to AEAT (Spain's tax agency) within four calendar days of issuance or receipt
Verifactu	January 1, 2027 (corporations); July 1, 2027 (self-employed)	All businesses and self-employed persons NOT already reporting through SII	Use of certified anti-fraud invoicing software that generates compliant, tamper-proof invoice records
Crea y Crece	Expected ~2027 (turnover above 8M EUR); ~2028 (all remaining businesses)	All domestic B2B transactions	Mandatory structured e-invoice exchange between businesses using approved formats and channels
TicketBAI	Live in Alava (2022) and Gipuzkoa (2024); Bizkaia completing rollout in 2026	All businesses and self-employed operating in the Basque Country provinces	Certified invoicing software that reports invoice data to the respective provincial tax authority before or at the time of issuance

Four critical relationships between these systems determine your obligations:

SII vs Verifactu exemption. Businesses already reporting through SII are explicitly exempt from Verifactu. The logic is straightforward: SII already provides AEAT with detailed, near-real-time invoice data, so the anti-fraud controls Verifactu introduces would be redundant for these taxpayers.
TicketBAI replaces Verifactu in the Basque Country. Taxpayers registered in Alava, Gipuzkoa, or Bizkaia follow TicketBAI rather than Verifactu. The Basque provinces operate their own fiscal frameworks, and TicketBAI predates Verifactu with similar anti-fraud objectives adapted to regional tax administration.
Verifactu and Crea y Crece are complementary, not alternatives. Verifactu governs how invoices are generated (certified software, anti-fraud controls, data integrity). Crea y Crece governs how invoices are exchanged between businesses (structured electronic format, approved transmission channels). Once both are fully enforced, many businesses will need to comply with both simultaneously for the same transaction.
FACe stands apart. B2G e-invoicing through FACe has been mandatory since 2015 and operates independently of the newer systems. According to the European Commission's eInvoicing country profile for Spain, Spain's FACe public e-invoicing platform processes more than 12 million e-invoices annually across over 8,000 public administrations. Any business invoicing the Spanish public sector must already comply, regardless of its obligations under SII, Verifactu, or Crea y Crece.

The practical result is that a mid-sized Spanish corporation selling to both government agencies and private businesses could face three concurrent obligations by 2028: FACe for public sector invoices, Verifactu-certified software for invoice generation, and Crea y Crece-compliant exchange for B2B transactions.

Spain is far from alone in this trajectory. Countries across Europe and beyond are layering real-time reporting, certified software mandates, and structured e-invoice exchange requirements on top of one another. South Africa's 2028 e-invoicing mandate, for instance, adopts a Peppol-based model driven by similar VAT fraud concerns. For a broader view of how these trends are unfolding worldwide, see our guide to global e-invoicing requirements and country mandates.

Each of Spain's systems carries distinct technical requirements, timelines, and penalty structures, starting with SII as the longest-running and most established of the four.

SII: Real-Time VAT Reporting for Large Companies

Spain's SII (Suministro Inmediato de Información) has been operational since July 1, 2017, established under Royal Decree 596/2016. Managed by AEAT (Agencia Estatal de Administración Tributaria), Spain's national tax authority, SII was the country's first major step toward real-time digital tax reporting and remains the compliance framework for its largest businesses.

Who Must Comply with SII

SII applies to a defined set of taxpayers:

Companies with annual turnover exceeding 6,010,121.04 EUR
Businesses registered under REDEME, Spain's monthly VAT refund scheme (Registro de Devolución Mensual del IVA)
VAT groups (agrupaciones de entidades a efectos del IVA)
Any business that voluntarily opts in, regardless of size

If your organization falls into any of these categories, SII is your primary compliance obligation for digital invoice reporting in Spain.

What SII Requires

SII is a reporting obligation, not an e-invoice exchange format. It does not dictate how you send invoices to your customers or receive them from suppliers. Instead, it requires near-real-time submission of structured invoice data to AEAT for both issued invoices (libro registro de facturas expedidas) and received invoices (libro registro de facturas recibidas).

This distinction matters. Under SII, you continue issuing invoices in whatever format your business uses. What changes is that the tax authority receives a digital record of every transaction almost as it happens, replacing the old quarterly summary returns with a continuous flow of granular data.

Submission Process and Deadlines

Invoice records must be submitted to AEAT within strict timeframes:

Issued invoices: Within 4 calendar days of the invoice issue date
Received invoices: Within 4 calendar days of the accounting registration date
Intra-community acquisitions: Within 8 calendar days of the invoice registration

Submission is handled through XML messages sent via AEAT's web services (SOAP-based). For businesses with low invoice volumes, AEAT provides a manual entry portal on its website, though this is impractical for any company processing invoices at scale.

Each XML submission contains detailed invoice-level data: counterparty identification, invoice number and date, taxable base amounts, VAT rates applied, and transaction type codes. AEAT validates these records and returns acceptance or rejection responses, meaning your systems need to handle error correction and resubmission workflows.

SII Penalties

Late or incorrect SII submissions carry financial consequences. The penalty structure is 0.5% of the reported invoice amount for each late submission, with a minimum of 300 EUR and a maximum of 6,000 EUR per quarter. These penalties apply per invoice, so a backlog of unreported transactions can accumulate significant fines quickly.

The SII Exemption from Verifactu

One critical detail for businesses already complying with SII: you are exempt from the Verifactu mandate. Because SII already provides AEAT with real-time visibility into your invoice data, the anti-fraud controls that Verifactu introduces for other businesses are considered redundant for SII-obligated taxpayers.

SII serves as the compliance path for Spain's largest companies. Verifactu extends similar anti-fraud controls to every business that falls below the SII thresholds.

Verifactu: Spain's Anti-Fraud Invoicing Software Mandate

Verifactu represents the most sweeping change to invoicing obligations for Spanish businesses in decades. Unlike SII, which targets only the largest companies, Verifactu applies to every business and self-employed person in Spain that does not already report through SII. That includes approximately 3.4 million autónomos (self-employed workers) alone.

The legal foundation has two layers. Law 11/2021, known as the Ley Antifraude (Anti-Fraud Law), established the requirement that all invoicing software used in Spain must be certified to prevent tax fraud. Royal Decree 1007/2023 then defined the detailed technical specifications that compliant invoicing systems must meet, covering everything from data integrity to communication protocols with AEAT.

Compliance Deadlines

The original Verifactu deadlines were set for 2026, but Royal Decree-Law 15/2025, published in December 2025, postponed them by one year. The current deadlines are:

January 1, 2027 for Corporate Income Tax taxpayers (corporations)
July 1, 2027 for self-employed persons (autónomos) and all other taxpayers

Any source showing 2026 deadlines is outdated and should be disregarded.

Core Technical Requirements

Verifactu-compliant invoicing software must satisfy three fundamental integrity requirements:

Hash chaining links each invoice record cryptographically to the previous one. Every new record includes a hash value derived from the prior record's data, creating an immutable chain. If any record is deleted or altered after the fact, the chain breaks, and the tampering becomes immediately detectable during an AEAT audit or inspection.

QR codes on all invoices allow AEAT to verify invoice authenticity. Each invoice must carry a QR code that encodes key invoice data, enabling tax inspectors or even invoice recipients to validate the document against AEAT's records.

Immutable records mean that once an invoice is generated, the original record cannot be modified or deleted. Corrections must be made through new corrective invoices, preserving the full audit trail.

Two Compliance Modes

Businesses can choose between two approaches to Verifactu compliance:

Verifactu mode requires invoicing software to transmit invoice records to AEAT in near-real-time, functioning similarly to SII but through certified software rather than direct API integration. This mode gives AEAT continuous visibility into a business's invoicing activity.

Non-Verifactu mode generates invoice records with all required integrity features (hash chaining, immutability, QR codes) but stores them locally rather than transmitting them to AEAT. Records must be available on demand for tax inspections. This mode offers more operational independence but still requires fully compliant software.

Both modes demand certified software. The difference is whether data flows to AEAT automatically or waits for a formal request.

Software Certification and Readiness Gaps

Every invoicing software product used by Spanish businesses must be certified as Verifactu-compliant under the specifications in Royal Decree 1007/2023. Software providers bear the responsibility of ensuring their products meet these standards before the deadlines.

This creates a significant practical problem. Widely used international platforms like QuickBooks and Xero are currently not Verifactu-compliant. Businesses relying on these tools will need to either wait for their providers to achieve certification, switch to compliant alternatives, or implement supplementary certified modules before the deadlines take effect.

Penalties

The penalty structure targets both sides of the software equation:

Software providers offering non-compliant invoicing software face fines of up to 150,000 EUR per year
Businesses using non-compliant software face fines of up to 50,000 EUR per year

These penalties apply per year of non-compliance, meaning continued use of uncertified software compounds the financial exposure rapidly.

Crea y Crece: Mandatory B2B E-Invoice Exchange

While Verifactu governs how invoicing software generates and reports invoice records, Ley Crea y Crece (Law 18/2022) addresses an entirely different layer of Spain's digital invoicing framework: how invoices are exchanged between businesses. This law mandates that all domestic B2B transactions in Spain must use structured electronic invoices, eliminating PDF and paper-based invoice exchange for inter-business commerce.

The distinction matters for compliance planning. Verifactu certifies your invoicing software and ensures tax authorities receive tamper-proof records. Crea y Crece requires that the actual invoice documents sent between buyer and seller follow a standardized electronic format and travel through accredited exchange platforms. These are parallel obligations, not alternatives.

Timeline: Two-Phase Rollout

The Crea y Crece B2B e-invoicing mandate will take effect in two phases, triggered by the publication of an implementing ministerial order:

Phase 1 (estimated ~2027, 12 months after the ministerial order): Businesses with annual turnover exceeding 8 million EUR
Phase 2 (estimated ~2028, 24 months after the ministerial order): All remaining businesses regardless of size

Important caveat: The ministerial order has not yet been published as of early 2026. These dates are estimates based on the legislative framework. Finance teams should monitor official publications from Spain's Ministry of Economic Affairs, but should not delay preparation given the scope of changes required.

Format Requirements and EU Alignment

E-invoices exchanged under Crea y Crece must comply with EN 16931, the European e-invoicing standard developed under EU Directive 2014/55/EU. This standard supports two syntaxes:

UBL (Universal Business Language) - the more widely adopted syntax across EU member states
CII (Cross-Industry Invoice) - an alternative syntax under the UN/CEFACT framework

Spain also accepts its national Facturae format, which has been used in public procurement e-invoicing since 2015. By adopting EN 16931 alongside Facturae, Spain aligns with the broader EU push toward cross-border e-invoicing interoperability, making it easier for businesses trading across multiple European markets to standardize their invoice formats.

The Platform Exchange Model

Under Crea y Crece, e-invoices will not be sent directly between businesses. Instead, they will flow through accredited public and private exchange platforms. This model resembles the approach being implemented in France with its Plateforme de Dématérialisation Partenaire (PDP) system. Each business will need to connect to at least one accredited platform capable of sending and receiving structured invoices on its behalf.

The platform model serves several purposes: it validates invoice format compliance before delivery, provides a verifiable audit trail for tax authorities, and creates a standardized infrastructure that reduces integration complexity for smaller businesses.

Dual Compliance: Verifactu and Crea y Crece Together

For many Spanish businesses, Crea y Crece will apply simultaneously with Verifactu. In practice, this means a business will need:

Verifactu-compliant invoicing software to generate invoice records with the required anti-fraud integrity controls and report them to AEAT
A Crea y Crece-accredited platform connection to exchange structured e-invoices with trading partners

These dual requirements reinforce each other but require separate technical preparations. Your invoicing software vendor must support Verifactu's anti-fraud controls, and your business must also onboard with an accredited exchange platform for B2B document transmission.

Spain is not building this framework from scratch. Italy's FatturaPA system that pioneered mandatory EU e-invoicing became the first nationwide B2B e-invoicing mandate in the EU when it launched in 2019. Spain's adoption of the pan-European EN 16931 standard rather than a purely national format positions Spanish businesses for smoother cross-border compliance as more EU member states follow suit.

TicketBAI: The Basque Country Regional System

Spain's fiscal autonomy framework grants the three Basque Country provinces, Alava, Gipuzkoa, and Bizkaia, their own independent tax authorities, separate from the national AEAT. Each province operates its own tax collection and enforcement system. TicketBAI is the regional invoicing control system these provinces developed to combat tax fraud, and it predates the national Verifactu mandate by several years.

Rollout Status

TicketBAI is already further along in implementation than Verifactu:

Alava has required TicketBAI compliance since 2022
Gipuzkoa made TicketBAI mandatory in 2024
Bizkaia is completing its phased rollout through 2026

This means that while the rest of Spain is still preparing for Verifactu's national deployment, thousands of Basque Country businesses are already operating under an equivalent anti-fraud invoicing regime.

Technical Requirements

TicketBAI uses a distinct TBAI XML format that differs from Verifactu's specification. Despite the format differences, the underlying anti-fraud principles are similar:

Chained invoice hashing where each invoice record is cryptographically linked to the previous one, creating a tamper-evident chain that tax authorities can verify
QR codes on all invoices requiring every issued invoice to include a QR code that links back to the TicketBAI system for verification
Province-specific submission protocols where each of the three Basque provinces maintains its own technical specifications, submission endpoints, and validation rules

TicketBAI and Verifactu: How They Interact

The critical point for compliance planning: Basque Country taxpayers use TicketBAI instead of Verifactu, not in addition to it. Because TicketBAI serves the same anti-fraud purpose at the regional level, businesses subject to Basque tax authorities are exempt from the national Verifactu mandate.

However, this exemption creates a specific challenge for businesses with operations spanning both jurisdictions. If your company has establishments in the Basque Country and elsewhere in Spain, you may need to comply with TicketBAI for your Basque operations and Verifactu for operations in the rest of Spain. Your invoicing software must support both systems, including their different XML formats, submission protocols, and validation requirements.

Spain E-Invoicing Timeline and Penalties

Spain's e-invoicing obligations have rolled out incrementally since 2015, with several more deadlines approaching through 2030. The timeline below consolidates every key date across all four systems into a single reference for compliance planning.

Consolidated timeline (chronological):

January 15, 2015: FACe B2G e-invoicing becomes mandatory for all suppliers invoicing Spain's public sector.
July 1, 2017: SII goes live for large companies, requiring real-time VAT reporting within four days of invoice issuance.
2022: TicketBAI becomes mandatory in Alava, the first Basque province to enforce the system.
2024: TicketBAI enforcement extends to Gipuzkoa.
2026: TicketBAI rollout completing in Bizkaia, covering all three Basque provinces.
January 1, 2027: Verifactu becomes mandatory for corporations (sociedades). This date was originally set for January 2026 but was postponed by one full year through Royal Decree-Law 15/2025, published in December 2025.
~2027: Crea y Crece Phase 1 takes effect for businesses with annual turnover above 8 million EUR, beginning 12 months after the ministerial order establishing technical specifications is published.
July 1, 2027: Verifactu becomes mandatory for self-employed individuals (autónomos) and all remaining taxpayers. This date was also pushed back one year from the original July 2026 deadline under the same Royal Decree-Law 15/2025.
~2028: Crea y Crece Phase 2 extends mandatory B2B e-invoice exchange to all remaining businesses, 24 months after the ministerial order.
July 1, 2030: The EU ViDA (VAT in the Digital Age) directive requires cross-border B2B e-invoicing across all EU member states.

A critical note on dates: Many English-language sources and even some Spanish government references still cite the original 2026 Verifactu deadlines. Royal Decree-Law 15/2025, published in December 2025, officially shifted both Verifactu milestones forward by one year. Verify that any compliance roadmap you are working from reflects the updated 2027 dates.

Penalty Reference by System

Non-compliance carries distinct financial consequences under each system. Finance teams should factor these into risk assessments when prioritizing implementation work.

SII penalties: Each invoice reported late incurs a penalty of 0.5% of the reported invoice amount, with a minimum of 300 EUR per infraction and a maximum cap of 6,000 EUR per quarter. For high-volume businesses processing thousands of invoices monthly, these penalties compound quickly.

Verifactu penalties: The penalty structure distinguishes between software providers and end users. Software providers that develop, market, or distribute invoicing software that does not meet Verifactu's technical requirements face fines of up to 150,000 EUR per year. Businesses that knowingly use non-compliant invoicing software face fines of up to 50,000 EUR per year. This dual-penalty model places responsibility on both sides of the software supply chain.

TicketBAI penalties: Each Basque province sets its own penalty schedule, though the structures follow similar patterns to Verifactu, targeting both software non-compliance and taxpayer non-compliance.

Crea y Crece penalties: The ministerial order establishing Crea y Crece's enforcement details has not yet been published. Penalty structures for non-compliance with the B2B e-invoice exchange mandate will be defined in that order.

The EU Cross-Border Layer Ahead

The July 2030 ViDA directive deadline adds another compliance dimension for businesses with cross-border operations. Companies trading across EU borders will eventually need to satisfy both Spain's national e-invoicing systems and the EU-wide structured e-invoicing requirements for intra-community transactions. France's parallel e-invoicing mandate rolling out in 2026 is another example of this broader European shift toward mandatory digital tax reporting. Businesses operating in multiple EU markets should plan for overlapping compliance obligations rather than treating each country's mandate in isolation.

How Spain's E-Invoicing Mandates Affect Invoice Recipients

Most guidance on Spain's e-invoicing mandates focuses on the issuer's perspective: how to generate compliant invoices, which software to certify, and what reporting deadlines to meet. But businesses that receive invoices from Spanish suppliers face their own set of operational changes as these mandates roll out. If your AP department processes invoices from vendors operating in Spain, here is what shifts in practice.

Verifactu changes what invoices look like. Invoices from Spanish suppliers will carry QR codes linked to AEAT's verification system and will be generated by certified software that maintains hash chain integrity between sequential invoices. For AP teams, this introduces a new validation opportunity. You can scan or verify QR codes as part of your invoice approval workflow to confirm that the document was generated by compliant software and has not been altered. While verification is not mandatory for recipients, building it into your process adds a layer of fraud protection at minimal cost.

Crea y Crece changes how invoices arrive. This is the most disruptive shift for recipients. B2B invoices will no longer arrive as PDF attachments or paper scans. Instead, they will be transmitted as structured electronic documents in UBL, CII, or Facturae XML format through Spain's public e-invoice exchange network. Your AP systems need the ability to receive, parse, and process these structured formats. Teams that rely on manual PDF review or basic email-based invoice collection will need to adapt their intake workflows.

SII changes the timing dynamic. If your suppliers are SII-obligated (annual turnover above EUR 6 million), they already report invoice data to AEAT within four days of issuance. This means the tax authority has visibility into your purchase transactions almost in real time. Discrepancies between what your supplier reports and what you eventually declare become easier for AEAT to flag, making accurate and timely invoice recording on the recipient side more important than before.

The transition period creates a mixed-format challenge. With Verifactu rolling out in 2027 and Crea y Crece following roughly 2027 through 2028, AP departments will not see a clean cutover from one format to another. During this multi-year transition, invoices from Spanish suppliers will arrive in a mix of formats: legacy PDFs, scanned images, PDFs with Verifactu QR codes and certification markers, and structured Facturae or UBL XML documents. Processing this mix manually or with tools built for a single format creates bottlenecks and increases error rates.

The ability to extract structured data from invoices in any format becomes critical for maintaining efficient processing across this transition. Rather than building separate workflows for PDF and paper invoices versus structured e-invoices, businesses can automate invoice data extraction from Spanish suppliers to handle the PDF and scanned invoices that will continue arriving during the changeover. A purpose-built extraction platform that processes PDFs and image files in any language, including Spanish, and outputs standardized Excel, CSV, or JSON files reduces the manual processing burden while your AP systems adapt to the new structured formats.

Preparing for Spain's E-Invoicing Requirements

With four overlapping systems and staggered deadlines, compliance preparation requires a structured approach. Use this checklist to identify your immediate priorities and build a realistic implementation plan.

1. Determine which systems apply to your business. Refer to the decision matrix earlier in this guide to map your obligations. Check your annual turnover against the SII threshold of 6,010,121.04 EUR and the Crea y Crece Phase 1 threshold of 8M EUR. Confirm whether your business is registered in the Basque Country provinces of Alava, Bizkaia, or Gipuzkoa, which trigger TicketBAI obligations instead of Verifactu. If you invoice Spanish public sector entities, verify your FACe compliance status. Most businesses will fall under at least two of these systems simultaneously.

2. Audit your invoicing software for Verifactu readiness. With the Verifactu deadline set for January 2027 (developers) and July 2027 (end users), software certification is the most time-sensitive action item. Contact your invoicing software provider directly and ask for their Verifactu certification timeline. If you rely on platforms like QuickBooks, Xero, or similar tools, do not assume they will be certified by the deadline. If your provider cannot confirm compliance, begin evaluating certified alternatives now. Switching invoicing software takes longer than most businesses anticipate.

3. Prepare for structured e-invoice exchange under Crea y Crece. Plan for connecting to an accredited e-invoicing platform that supports the required formats: EN 16931 (UBL 2.1 or CII) and Facturae 3.2.x. Research platform options, request demos, and compare pricing before the mandate takes effect. Waiting until the mandate is live will limit your options and increase implementation costs.

4. Update your accounts payable workflows. If you receive invoices from Spanish suppliers, the format transition will affect your operations regardless of where your business is headquartered. Ensure your invoice processing tools can handle structured e-invoice formats (UBL, CII, Facturae) alongside the PDF invoices you currently receive. Building this capability ahead of the mandate prevents processing delays when your suppliers begin sending structured invoices.

5. Monitor regulatory developments closely. The Crea y Crece ministerial order defining technical specifications has not yet been published, and implementation details may shift before final adoption. Follow AEAT communications for updates on Verifactu certification lists and Crea y Crece platform accreditation. Track related EU-level mandates, particularly ViDA (VAT in the Digital Age), which will introduce cross-border digital reporting requirements that interact with Spain's domestic systems.

Spain is part of a broader EU movement toward mandatory e-invoicing, and businesses operating across multiple member states face compounding compliance requirements. Poland's KSeF national e-invoicing platform follows a similar trajectory with its own mandatory structured invoicing mandate, adding another layer of complexity for organizations with pan-European operations. Each country's system has different formats, timelines, and technical requirements.

By 2028 to 2030, Spain's SII, Verifactu, and Crea y Crece mandates will be fully operational and converging with EU-wide ViDA requirements. The businesses that map their obligations now, confirm their software vendors' Verifactu certification timelines, and build intake workflows that handle both PDF and structured e-invoice formats will absorb each new deadline with minimal disruption rather than scrambling at each enforcement date.