Spain's e-invoicing mandate and Verifactu: what applies and when
Spain has two separate duties. B2B e-invoicing in a structured format starts on 6 October 2027 for larger businesses and 6 October 2028 for everyone else, under a ministerial order published on 5 October 2026. Verifactu, a rule for invoicing software, is a different measure with its own, delayed dates. Below: the dates as reported, what each is, and what a free local checker covers.
B2B e-invoicing: the timeline (as reported)
| Date | What changes |
|---|---|
| 5 Oct 2026 | Order HAC/1028/2026 is published in the BOE with the technical specifications of the public e-invoicing solution. It takes effect on 6 Oct 2026. |
| 6 Oct 2027 | Businesses and professionals whose turnover in the previous calendar year exceeded 8 million euro must issue B2B invoices electronically. |
| 6 Oct 2028 | All other businesses and professionals in scope follow. Individuals and attribution-regime entities at or under 8 million euro are reported to get a further 12 months for the invoice-status communication. |
Format as reported: invoices sent through the public solution use the EN 16931 semantic model in UBL. A business that uses a private platform must also send a faithful electronic copy of each invoice to the public solution. During the first 12 months of the larger-business phase a readable PDF is reported to accompany the structured invoice unless the recipient agrees otherwise. The BOE's own search listing (read 2026-10-27) agrees on the legal chain: Order HAC/1028/2026 (BOE-A-2026-20587, in force 6 Oct 2026) starts the clocks that Royal Decree 238/2026 (BOE-A-2026-7295, 25 March 2026) sets as 12 months for businesses above 8 million euro and 24 months for the rest, and the Tax Agency posted first technical documentation for developers on 13 Oct 2026. Unconfirmed: these facts come from advisory and news summaries (EY, KPMG, Seeburger, Fiscal Solutions, peppol.nu, VATupdate) read as search excerpts on 2026-10-27; the BOE text was not read, and exemptions, the status-communication rules and any penalty are not stated here. This is a summary, not tax advice; confirm with your adviser or the AEAT.
Verifactu: the timeline (as reported)
| Date | What changes |
|---|---|
| 1 Jan 2027 | Corporate taxpayers outside the SII immediate-supply reporting regime must use compliant invoicing software. |
| 1 Jul 2027 | Other businesses and self-employed people who use invoicing software follow. |
Exemptions exist (for example taxpayers under TicketBAI in the Basque Country and Navarra). The ministerial order with the technical rules must be issued first, so the dates are working targets. As of 24 October 2026, Real Decreto-ley 15/2025 still sets the dates above; the Finance Ministry is reported to be considering a further postponement (some obligations to October 2028, aligned with the B2B e-invoicing duty), but we found no BOE text adopting it, so plan to the enacted dates until one appears. This is a summary from secondary sources, not tax advice; confirm with your adviser or the AEAT.
What it covers, and what it does not
Verifactu is about the software: invoice records that cannot be altered unnoticed, a QR code on the invoice and, in one mode, submission of each record to the AEAT. It is not a Peppol mandate and not the separate B2B e-invoicing duty above, which is about sending structured invoices to customers.
What this checker does and does not do
It does not read Verifactu records. It reads JSON, UBL, CII and Factur-X files and applies the EN 16931 and Peppol BIS 3.0 rules: arithmetic, tax breakdown, VAT, IBAN and BIC typos, each with a rule ID and a fix (the rule reference). Open the checker; no account, nothing uploaded.
No invoice yet? The e-invoice creator turns a form into UBL or CII XML and checks it. Other countries: Germany, France, Belgium, Poland and Croatia, Italy, Romania, Greece, Bulgaria, the UK, the UAE, India, Saudi Arabia, or the Portugal, EU e-invoicing mandate checker. Also: Slovakia, Lithuania, Luxembourg, Malta, Norway, Hungary, Denmark, Estonia, Latvia, Slovenia, Czech Republic, Serbia.
Common questions
When does Spain's B2B e-invoicing mandate start?
Order HAC/1028/2026, published in the BOE on 5 October 2026, is reported to set 6 October 2027 for businesses and professionals whose previous-year turnover exceeded 8 million euro and 6 October 2028 for all others in scope. The dates come from advisory and news summaries, not the BOE text, so confirm them before relying on them.
Which format does Spain's B2B e-invoice use?
As reported, invoices sent through the public solution use the EN 16931 semantic model in UBL, and businesses on private platforms must also send a faithful electronic copy to the public solution. So the safest test is an EN 16931 UBL file. The order's own technical annex was not read.
What is Spain's Verifactu deadline?
Verifactu is Spain's anti-fraud rule for invoicing software: programs must produce tamper-evident invoice records, and many send them to the Tax Agency (AEAT). After a delay approved in December 2025 (Royal Decree-Law 15/2025), the reported dates are 1 January 2027 for corporate taxpayers outside the SII regime and 1 July 2027 for other businesses and self-employed people who use invoicing software. The technical order that fixes the rules must be issued first, so confirm the dates with your adviser or the AEAT.
Is Verifactu the same as e-invoicing?
No. Verifactu governs how invoicing software records and, optionally, reports invoices to the tax authority. Spain's separate B2B e-invoicing duty (the Crea y Crece law) has its own timeline: 6 October 2027 for businesses with turnover above 8 million euro and 6 October 2028 for the rest, as reported. Neither is a Peppol mandate like Belgium's.
Can this checker validate Verifactu records?
No. It does not read Verifactu records or QR codes. It reads JSON, UBL, CII and Factur-X invoices and applies the EN 16931 and Peppol BIS 3.0 rules, which helps with the invoice content itself: totals, tax breakdown, VAT, IBAN and BIC typos, each with a rule ID and a fix.
How do I check an invoice before sending it to a Spanish customer?
Drop the file into the checker. Nothing is uploaded when you use the page. It is an offline observation, not the tax authority's acceptance and not legal advice.
Open the E-invoice Preflight checker to validate your own invoice file.
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