Spain's live obligation is about the software that issues the invoice, not the format the invoice takes. Businesses that invoice with software must run a system that produces a tamper-evident record of every invoice — before 1 January 2027 if they pay corporate income tax, and before 1 July 2027 otherwise. Business-to-business e-invoicing is a separate law with no date yet. GoRoute delivers the structured invoice itself across the EU from one e-invoicing platform and one API.
Not between businesses, not yet. What is mandatory is the invoicing system. Under the regulation approved by Real Decreto 1007/2023, a business that issues invoices with software must use a system that produces a tamper-evident record of every invoice. Corporate income tax payers must have adapted their systems before 1 January 2027; everyone else in scope, before 1 July 2027.
Those two dates are recent. Real Decreto-ley 15/2025 of 2 December moved them a full year, from 1 January and 1 July 2026, and the Agencia Tributaria published a notice saying so. A plan written from a page that has not been updated since early 2025 is working to dates that no longer exist. Spain sits alongside every other mandate in our e-invoicing mandates tracker.
The separate thing people usually mean by "e-invoicing in Spain" — businesses having to send each other structured electronic invoices — is Ley 18/2022, the Crea y Crece law. It is passed and it has never started. The section on it below explains what has to happen first.
Spain asks four separate things, and they are routinely collapsed into one word, "Verifactu". Two are about the software, one is about what appears on the document, and one is a law that has not started. Each carries its own date, and the sections after this table take them one at a time.
| Obligation | Applies to | Date |
|---|---|---|
| Compliant products on the market | Producers and sellers of invoicing software, who self-certify each version by a responsible declaration | Since 29 July 2025 |
| An adapted invoicing system | Corporate income tax payers that issue invoices with software | Before 1 January 2027 |
| An adapted invoicing system | The remaining taxpayers in scope — personal income tax payers with business income, non-residents with a permanent establishment, and income-attribution entities | Before 1 July 2027 |
| QR code on the invoice | Every invoice a business in scope issues, complete or simplified | From the date above that applies to it |
| Structured invoices between businesses | All businesses and professionals, under Ley 18/2022 (Crea y Crece) | No date — the implementing regulation has not been approved |
Verifactu is one of two ways of complying, not the obligation itself. Every invoicing system in scope has to produce an invoicing record — a structured entry created at the moment the invoice is issued, carrying the invoice's mandatory data plus security fields, the identity of the system that made it, and the date and time it was made. Verifactu decides what happens to that record next.
| Mode | Where the records go | What the system must add |
|---|---|---|
| Verifactu | Sent to the Agencia Tributaria as they are produced | A hash chain across records |
| Non-Verifactu | Kept in the issuing system, and sent to the tax administration on request through a simplified automated procedure | The same hash chain, plus an electronic signature on each record and a system event log kept to comparable security requirements |
The hash chain is the mechanism behind the word "inalterable". Each record's hash is computed over parts of the record immediately before it, so records form a sequence in which removing or editing one breaks every hash after it. That is what the regulation means when it asks for integrity, traceability and inalterability with no interpolations or omissions left unrecorded.
Two things follow that surprise people, and both come from the tax agency's own wording. First, an invoicing record is not an electronic invoice. It does not carry everything the invoice carries, and the agency says in terms that these records are in no case electronic invoices. Second, and because of that, paper invoices are still allowed. A business can print an invoice and hand it over, and still owe a compliant record for it. Structured electronic invoicing is permitted too, and neither choice is altered by the record obligation.
Every system produced and sold, in either mode, has to be able to export its records and transmit them online. And for the smallest businesses — those issuing too few invoices to want a system at all — the Agencia Tributaria provides a form in its own electronic office that produces a printable invoice with a QR and keeps the record. That free application is Verifactu-mode, it needs the customer fully identified so it cannot be used for simplified invoices, and it does not handle invoices with multiple recipients.
The scope is wide and the exclusions are specific. In scope are businesses and professionals — individuals or companies — established in Spain who issue invoices: corporate income tax payers, personal income tax payers with business income, non-resident income tax payers operating through a permanent establishment in Spain, and income-attribution entities carrying on an economic activity. It applies to complete and simplified invoices alike, whoever the customer is, and it applies even where only part of the business runs on the software.
The Agencia Tributaria expresses the exclusions as four conditions that must all hold before the rules bite — it calls this the rule of the four "no"s. A business is outside the rules if any one of them fails:
Transactions that do not have to be documented by an invoice at all are outside this as well, and so are those covered by a specific authorisation not to invoice. The regulation does not change what has to be invoiced — it changes how the software that does the invoicing must behave.
A QR code. From the point the requirements take effect for a business, every invoice it issues — complete or simplified — carries one. The code holds some of the invoice's data and a web address at the Agencia Tributaria. Invoices issued by a Verifactu system also carry a legend marking them as verifiable.
What the QR is for depends on the mode. On a Verifactu invoice it lets the recipient check the invoice's contents against what the tax agency already holds. On a non-Verifactu invoice it is the route by which the recipient can report the invoice to the tax authorities, because the agency has not been sent the record. Same code, two jobs.
This is the only change the regulation makes to the invoice as a document. Everything else about Spanish invoicing content is unchanged and continues to be governed by the VAT law and the invoicing-obligations regulation. If the structured-document side is unfamiliar, what a UBL invoice is is the shorter read, and how the Peppol network works covers delivery.
Corporate income tax payers before 1 January 2027; the rest of the taxpayers in scope before 1 July 2027; producers and sellers of invoicing software since 29 July 2025, which was nine months after the order setting the technical specifications took effect.
The two taxpayer dates moved recently and it is worth being exact about the sequence, because published guidance is still catching up. The regulation was approved by Real Decreto 1007/2023 of 5 December. Orden HAC/1177/2024 of 17 October added the technical, functional and content specifications. Real Decreto 254/2025 of 1 April set the taxpayer deadlines at 1 January and 1 July 2026. Then Real Decreto-ley 15/2025 of 2 December replaced those with 1 January and 1 July 2027, and the Agencia Tributaria published a notice confirming the new dates.
The period before each date is a testing period, in the agency's own framing: a business may send test records with a Verifactu-mode system and go on invoicing with a different system, up to the deadline for having its systems adapted.
One detail worth carrying into a procurement plan: multi-year maintenance contracts signed before the software makers' deadline still have to be brought into line by the taxpayer dates above. An old contract does not buy extra time.
A note on the word "certified", because it means something unusual here. There is no external certification body and no register of approved products. The producer of the software certifies its own product, for each version, by a responsible declaration that has to be visible inside the product and available to the customer and the reseller at the point of purchase. A reseller that is not the producer has to satisfy itself that what it sells carries the producer's declaration. So "certified for Verifactu" on a vendor's website is that vendor's own statement, and it is worth reading the declaration rather than the marketing.
No, and no clock is running. Article 12 of Ley 18/2022 — the Crea y Crece law — requires all businesses and professionals to issue, send and receive electronic invoices in their dealings with one another, and requires both parties to report invoice status. That text has been law since 2022. It has never taken effect.
Two conditions stand between the text and the obligation, and both are in the law itself. It takes effect one year after the implementing regulation is approved for businesses and professionals turning over more than eight million euros a year, and two years after for everyone else. Separately, its entry into force is conditional on Spain obtaining a derogation from articles 218 and 232 of the EU VAT Directive. No implementing regulation has been approved, so neither the one-year nor the two-year clock has started.
What the law already commits to is worth knowing before choosing a supplier, because it constrains the market that will exist when the date arrives. Platforms offered by e-invoicing service providers must interconnect and interoperate with each other free of charge, and so must businesses' own in-house platforms. A recipient may not force the issuer to use a particular solution, platform or provider. Recipients may ask for a copy of an electronic invoice for four years from issue without extra cost. And the systems that handle and store these invoices must meet the same invoicing-system requirements described above.
The practical reading for a business planning capital spend: the invoicing-system dates are real and close, and the business-to-business mandate is real but unscheduled. Building for the first, on infrastructure that can already exchange structured invoices, leaves the second as a configuration rather than a project. Spain's neighbours are further along and their calendars are firm — France, Portugal and Italy each run a different model, and the global view sets them side by side.
Read the scope test before assuming anything. The invoicing-system rules reach businesses and professionals established in Spain who issue invoices, including non-residents operating through a permanent establishment there. A supplier with no establishment in Spain, invoicing a Spanish customer from elsewhere, is not the addressee of those rules — and the invoicing obligations of its own country still apply to it in full.
That is the general shape rather than a ruling on a particular business. Whether a specific arrangement creates a permanent establishment in Spain, and whether a group's Spanish entity is caught, are questions for the Agencia Tributaria or a Spanish adviser, and the answer is worth having in writing before a project plan rests on it. This page will not answer it for you, and no vendor page should.
What is settled is the delivery side. Nothing in the Spanish regulation requires a particular exchange network, and the business-to-business mandate that will is not yet in force. So a supplier trading with Spain today sends the invoice the way it and its customer agree — and where that is a structured document over an interoperable network, the work is already done for the day the mandate arrives. A Spanish subsidiary of a group already exchanging UBL invoices elsewhere in Europe is closer to Spanish readiness than one running a Spain-only billing tool.
One boundary to be clear about. GoRoute is a Peppol certified Access Point and SMP provider; what we ship is the structured document and its delivery, not a Spanish billing package. The invoicing record, its hash chain and the producer's responsible declaration belong to the software that issues your invoices. Where that is a system we integrate with rather than one we supply, those obligations stay with its producer, and we say so rather than implying otherwise. Our Odoo integration is one example of that shape of connection, and the API is the general case for a system we have not met before.
Spain's regulation governs the software that issues invoices. It requires a tamper-evident record for every invoice, a hash chain linking the records, and a QR code on the document itself.
The producer self-certifies each version of its invoicing software; there is no external certification body and no register of approved products.
Records go to the tax agency as they are made, or stay in the issuing system with a signature and an event log.
Carries some of the invoice data and a web address at the Agencia Tributaria.
Invoicing record
One structured record per invoice, at the moment it is issued
Hash chain
Each record hashed over the one before it, so an edit breaks the sequence
Export and transmit
Every system must be able to export its records and send them online
QR code
On every invoice, complete or simplified, once the rules apply
Structured invoices on the European standard, ready for any EU trading partner.
Delivery across the EU as a Peppol certified Access Point, with our own SMP on the European rails.
A single REST API into the billing system you already run, rather than a replacement for it.
Spain alongside every other country on your roadmap, on one integration.
Documents checked against the rules of the receiving profile before they leave.
Structured EN 16931 invoices, Peppol delivery across the EU, and one API into the billing system you already run.
Official source: Agencia Tributaria — Sistemas Informáticos de Facturación (SIF) y VERI*FACTU. Dates and scope on this page were read there on 30 August 2026, against the agency's own notice on the extended deadlines and its frequently asked questions. Always confirm current obligations against the authority directly.
Primary texts: Real Decreto 1007/2023 as amended by Real Decreto 254/2025 and Real Decreto-ley 15/2025; Orden HAC/1177/2024; Ley 18/2022, article 12 and final provision eight.
Related reading: E-invoicing mandates 2026: a country-by-country tracker — Spain's dates alongside every other mandate in flight.
Not between businesses, not yet. What is mandatory is the invoicing system: under the regulation approved by Real Decreto 1007/2023, businesses that issue invoices using software must use a system that produces a tamper-evident invoicing record for every invoice. Corporate income tax payers must have adapted their systems before 1 January 2027, and everyone else in scope before 1 July 2027. Business-to-business electronic invoicing under Ley 18/2022 has no date at all yet.
Verifactu is one of the two ways of meeting Spain's invoicing-system rules. A Verifactu system sends each invoicing record to the Agencia Tributaria as it is produced. The alternative, which the tax agency calls the non-Verifactu mode, keeps the records in the issuing system instead, and in exchange has to sign each record electronically and keep a system event log. Both are valid; the choice is the business's.
The tax agency sets out four conditions, all of which must hold for the rules to apply. A business is out of scope if it invoices only by hand with no software, if it is enrolled in the Immediate Supply of Information regime for VAT records, if its tax domicile is in the Basque Country or Navarre, or if it holds a decision in force exempting it. Businesses in the Canary Islands, Ceuta and Melilla are in scope.
Corporate income tax payers must have their invoicing systems adapted before 1 January 2027, and the remaining taxpayers in scope before 1 July 2027. Those dates were set by Real Decreto-ley 15/2025 of 2 December, which moved them a year later than the 2026 dates that had been in force. Producers and sellers of invoicing software had to offer fully compliant products from 29 July 2025, nine months after the technical specifications took effect.
Yes, once the rules apply to the business issuing it. The Agencia Tributaria states that from the point the invoicing-system requirements take effect for a business, every invoice it issues, complete or simplified, carries a QR code, and that the code contains some of the invoice data and a web address at the tax agency. Invoices issued by a Verifactu system also carry a legend marking them as verifiable.
No date has started running. Article 12 of Ley 18/2022, the Crea y Crece law, requires all businesses and professionals to issue, send and receive electronic invoices with one another — but the law makes that take effect one year after an implementing regulation is approved for businesses turning over more than eight million euros, and two years after for everyone else. The law also makes it conditional on Spain obtaining a derogation from articles 218 and 232 of the EU VAT Directive. No implementing regulation has been approved.
