VeriFactu Spain 2026: Key Information for Businesses on the New Certified e-Invoicing Regulation
-
Countries
-
23 October 2025
-
16
Learn how Spain's new VeriFactu regulation, effective from 2026, will transform e-invoicing and tax compliance.
This overview includes key deadlines, system requirements, exemptions, and guidance on integrating VeriFactu with SAP systems.
Latest Updates on VeriFactu (Spain 2025)
- April 2025: The AEAT launched the first VeriFactu web services through its Electronic Office, enabling early testing for developers.
- November 2024: Implementation deadlines were officially postponed to January and July 2026 (Royal Decree 1007/2023 amendment).
- October 2024: The AEAT published detailed technical specifications and examples of the required responsible declaration for certified billing systems.
A New Phase in Spain’s Digital Tax Transformation
Spain is set to implement VeriFactu, a certified e-invoicing framework established under Royal Decree 1007/2023 and officially approved in December 2023. This new system will redefine how businesses issue and store invoices. Building on the Suministro Inmediato de Información (SII) system introduced in 2017, VeriFactu establishes stringent technical standards for billing software to ensure transparency, traceability, and compliance with anti-fraud measures.
In April 2025, the Spanish Tax Agency (AEAT) released its first VeriFactu services via its Electronic Office, allowing businesses and software developers to begin early testing and adaptation.
This regulation is part of Spain's broader digitalization strategy and aligns with upcoming EU initiatives under VAT in the Digital Age (ViDA).
Compliance Requirements and Schedule
VeriFactu applies to Spanish resident taxpayers using electronic invoicing systems who are not currently reporting transactions through SII. Compliance will be mandatory according to the following timeline:
- 1 January 2026: Legal entities subject to Corporate Income Tax (CIT)
- 1 July 2026: Self-employed individuals and other non-CIT taxpayers
Originally planned for July 2025, the implementation was postponed to 2026 to allow additional adaptation time. Businesses already reporting under SII are generally exempt, as their real-time VAT submissions align with the transparency objectives of VeriFactu.
Scope and Exemptions
VeriFactu is applicable throughout Spain, except in territories with their own fiscal regimes that may implement equivalent systems. This requirement does not apply to taxpayers already subject to real-time reporting obligations under SII. The SII system is mandatory for large companies (those generating more than €6 million in annual turnover), although all Spanish taxpayers may voluntarily opt in.
However, billing system requirements do not apply to SII taxpayers conducting self-billing or issuing invoices on behalf of third parties as required by law. When invoices are issued on behalf of a third party under a private agreement, the issuer must still comply with VeriFactu requirements, even if they are reporting under SII.
Non-resident entities holding a Spanish VAT number will not be affected unless they maintain a fixed establishment in Spain. Additionally, taxpayers exempt from invoicing obligations, who do not issue invoices, are outside the scope of VeriFactu.
Compliance Approaches for VeriFactu
Organizations subject to the VeriFactu regulation must choose between two compliance models: VeriFactu and non-VeriFactu.
While the term “VeriFactu” is commonly used to refer to this obligation, it encompasses two distinct approaches to meet Spain's certified billing requirements:
1. VeriFactu – Real-Time Reporting Model
Under this model, invoice data is automatically submitted to the Spanish Tax Agency (AEAT) at the time of issuance, enabling direct verification through the tax authority’s online portal.
Key Advantages of the VeriFactu Model:
- Simplified technical setup: No digital signature or event logging is required in the invoice register.
- Enhanced customer transparency: Invoices can be verified in the AEAT portal, fostering trust and credibility.
- Secure, compliant archiving: Invoice data is backed up with the tax administration, ensuring proper record-keeping.
- Improved tax support: With transaction data readily available to the authorities, services such as pre-filled VAT returns and VAT books may be offered.
- Reduced audit pressure: Real-time data visibility typically results in lower scrutiny during tax checks, particularly with VAT refund processes.
2. Non-VeriFactu – Certified Local Compliance Model
Alternatively, organizations may opt to comply without submitting invoice data in real-time under the non-VeriFactu model, which introduces greater technical and compliance complexity.
Key Considerations for the Non-VeriFactu Model:
- Higher technical requirements: Systems must incorporate a digital signature, event logging, and secure record-keeping for a minimum of four years.
- Increased audit exposure: Without direct visibility into transactions, audits may be more frequent or detailed.
- Limited access to tax services: Certain AEAT-provided tools, such as pre-filled VAT returns, will not be accessible.
For most organizations, the VeriFactu model offers a more sustainable path, especially when integrated with ERP platforms like SAP.
Technical Requirements Overview
To achieve VeriFactu compliance, invoicing systems must:
- Ensure the immutability and traceability of all invoice records.
- Generate invoices with unique sequential identifiers and digital signatures.
- Maintain an auditable chain of hashes linking all issued invoices.
- Record creation, correction, and cancellation events in a standardized XML format.
- Support optional real-time submission to AEAT through secure APIs.
Additionally, compliant billing software must include a "responsible declaration" (declaración responsable), a form of self-certification confirming that the billing system meets VeriFactu's legal and technical standards. Further details will be clarified in the forthcoming Ministerial Order issued by the Spanish Tax Agency.
Business Impact and Next Steps
For companies operating in Spain, VeriFactu presents both a regulatory challenge and an opportunity for digital transformation in tax and billing processes.
To prepare, organizations should:
- Assess whether they fall under SII or VeriFactu obligations.
- Evaluate their invoicing systems for technical readiness.
- Establish an implementation roadmap aligning with AEAT guidelines.
- Integrate VeriFactu processes into their VAT Control Framework.
Businesses adopting the VeriFactu model will enjoy simplified technical requirements, greater transparency, and improved automation through AEAT-provided support services, such as pre-filled VAT returns and VAT books.
Early preparation will help minimize disruption and ensure a smooth transition leading up to the 2026 deadlines.
KGT’s Perspective
At KGT, we view VeriFactu as a logical progression in Spain’s movement towards real-time, certified tax reporting.
Our experts combine extensive knowledge of SAP tax integration, e-invoicing frameworks, and compliance automation to assist organizations in achieving sustainable readiness for VeriFactu.
Whether you are currently operating under SII or will need to adopt VeriFactu by 2026, KGT offers the strategic and technical guidance necessary to ensure seamless alignment between your SAP system, tax data, and regulatory obligations.
How Can KGT Support You?
KGT has created an SAP-integrated e-invoicing add-on solution for Spain, featuring outbound and inbound functionalities to meet tax reporting requirements. This add-on includes a data extractor and a cockpit for generating periodic electronic invoices in the legal format and controls before submission. When SAP DRC launched the Spanish e-invoicing solution as part of its e-document offerings, KGT emerged as a leading consultancy firm for SAP DRC and tax services. Recognized as an SAP DRC partner for Spanish e-invoicing services, KGT is one of SAP's recommended implementation partners for this solution. We provide comprehensive support, including installation, configuration, customization, and training, to help you maximize the long-term value of your SAP DRC investment.
KGT is an SAP partner for PE services and an SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at: https://partnerfinder.sap.com/profile/0001925409