E-invoicing in Spain will become mandatory from 2027. Spain is not relying on a single system, but on two separate pillars: Verifactu defines the technical requirements for billing software, while the new B2B e-invoicing regime governs the structured exchange of invoices between businesses.

For German companies doing business with Spain, it is crucial to understand who will be affected from which date, which formats such as UBL, EDIFACT, Peppol or Facturae are accepted, and how much time remains to adapt existing systems. This article provides a structured overview of e-invoicing in Spain from 2027, explains Verifactu and the B2B mandate, highlights the key deadlines and outlines how to prepare your ERP and EDI landscape in a pragmatic way, especially for logistics flows between Hamburg and Spain.

Two Systems, One Country: E-Invoicing Spain between Verifactu and Crea y Crece

Spain is taking a different route than Germany. While the German e-invoicing mandate is built around a single system with staged obligations from 2025/2027/2028, Spain is moving to a dual model:

• Verifactu (Royal Decree 1007/2023) – an anti-fraud regime for invoicing software
• Mandatory B2B e-invoicing (Royal Decree 238/2026 / Ley Crea y Crece) – structured exchange of invoices between businesses

Both frameworks pursue different objectives, apply in parallel and often affect the same companies. Any business issuing or receiving invoices in Spain needs to be familiar with both.

On top of that, there are regional rules in the Basque Country (TicketBAI) and the long-standing B2G system FACe for invoices to public authorities. This makes Spain one of the more complex e-invoicing markets in Europe.

What is Verifactu?

Verifactu is an anti-fraud system run by the Spanish tax authority AEAT (Agencia Estatal de Administración Tributaria). It defines which technical requirements invoicing software must meet, but it does not regulate how invoices are exchanged between parties.

Technical basics:

• Legal basis: Royal Decree 1007/2023, amended by Royal Decree-Law 15/2025
• Scope: Invoicing software (SIF – Sistemas Informáticos de Facturación)
• Mandatory elements: QR code on every invoice, hash chain, digital signature, tamper-proof logging
• Two modes: VERIFACTU (real-time transmission to AEAT) or non-VERIFACTU (local storage only)
• Penalties: Up to EUR 50,000 per year for non-compliant users, up to EUR 150,000 per year for software vendors

The objective of Verifactu is to ensure tamper-proof invoicing. Each invoice receives an immutable digital fingerprint that refers to the previous invoice. Any manipulation breaks the chain and becomes immediately detectable.

Key dates (as of May 2026):

• 1 January 2027: Spanish corporate income tax payers (Sociedades)
• 1 July 2027: Other taxpayers (self-employed and partnerships)

These dates were set by Royal Decree-Law 15/2025 on 2 December 2025. Initially, the go-live had been planned for January/July 2026.

What is the B2B E-Invoicing Regime (Ley Crea y Crece)?

The second pillar is the mandatory structured B2B e-invoicing regime, comparable to the mandates in Belgium or Poland.

Technical basics:

• Legal basis: Royal Decree 238/2026 (adopted on 25 March 2026, published on 31 March 2026), based on Law 18/2022 “Crea y Crece”
• Architecture: Hybrid model combining private platforms with a central public platform (SPFE) operated by AEAT
• Formats: UBL (reference syntax for SPFE), CII (Cross-Industry Invoice), EDIFACT, Facturae. Peppol BIS is recognised as a UBL-based variant
• Mandatory status messages: Acceptance/rejection and payment date must be reported within 4 working days
• Transitional phase: During the first year, large enterprises are required to attach a PDF copy to the structured e-invoice

Expected go-live dates:

• ~October 2027: Companies with annual turnover above EUR 8 million
• ~October 2028: All other companies and self-employed persons

The exact dates are not yet final. They will be triggered by a Ministerial Order expected before 1 July 2026. From the publication of this Order, the 12- and 24-month deadlines start to run.

Key difference to Germany: Spain requires mandatory feedback on invoice status. An invoice is only considered paid once the money has actually arrived in the supplier’s bank account, not when a factoring facility is made available. The aim is to reduce late payments, a long-standing issue in the Spanish economy.

Verifactu vs. B2B E-Invoicing: Main Differences

Both systems interact but cover different parts of the process. A company established in Spain will have to comply with both from 2027 onwards.

What Does E-Invoicing in Spain 2027 Mean for Companies?

The combination of Verifactu and B2B e-invoicing will significantly change how Spanish businesses handle invoices: issuance becomes tamper-proof, exchange becomes fully structured and status messages become mandatory.

For German companies with links to Spain, the key questions are:

• Do you have a Spanish subsidiary or permanent establishment?
• To what extent do you work with Spanish customers and suppliers?
• Which formats and channels do you use today (PDF, classic EDI, Peppol, Facturae)?

The answers determine your exposure to the Spanish mandates.

Do German companies have to use Verifactu?

The short answer: No, as long as you do not have a permanent establishment in Spain.

According to Article 3 of Royal Decree 1007/2023, Verifactu applies to:

• Corporate income tax payers resident in Spain
• Personal income tax payers (self-employed) resident in Spain
• Non-residents with a permanent establishment in Spain
• Partnerships engaged in economic activities in Spain

Three common scenarios for German companies:

Scenario 1: Exports from Germany, no presence in Spain

You issue invoices from your German ERP system to Spanish customers. Verifactu does not apply to you. Your German invoicing software does not have to comply with the Verifactu specifications.

Scenario 2: Subsidiary or permanent establishment in Spain

Your Spanish entity is fully in scope of Verifactu. The invoicing software used in Spain must be adapted by January 2027 (corporations) or July 2027 (self-employed).

Scenario 3: Spanish customers request structured e-invoices

From 2027/2028 onwards, your Spanish customers must exchange structured B2B e-invoices between themselves. They will increasingly expect foreign suppliers to support compatible formats, even if there is no immediate legal obligation for you as a German exporter.

The Five Main Formats in Detail

Royal Decree 238/2026 allows four primary formats for B2B e-invoicing, plus Peppol BIS as a recognised variant:

UBL (Universal Business Language)

Reference syntax for the public SPFE platform. Even if you use a private platform, you must send a UBL copy of each invoice to SPFE. UBL is EN 16931-compliant and implements the EU Directive 2014/55/EU on e-invoicing in public procurement.

CII (Cross-Industry Invoice)

UN/CEFACT standard, also known as XML CEFACT. Widely used in international supply chains. Approved for exchange between private platforms.

EDIFACT

The classic EDI standard. Spain explicitly recognises EDIFACT due to its widespread use across many sectors of the economy. Particularly relevant for logistics, automotive and maritime industries.

Facturae

Spanish XML standard established through the B2G platform FACe. Mandatory since 2015 for invoices to public authorities. Continues to be allowed in B2B scenarios due to its broad penetration in the Spanish market.

Peppol BIS

Recognised in the private platform ecosystem because it uses UBL syntax and is EN 16931-compliant. Companies that already use a Peppol Access Point for other EU countries (e.g. Belgium, Poland, Germany) can in principle reuse the same connection for Spain.

Important: A pure PDF invoice does not qualify as an e-invoice under the Spanish regime. It may only be sent as an additional human-readable copy during the 12-month transition period.

Other Points to Consider

TicketBAI in the Basque Country

The three Basque provinces Álava, Bizkaia and Gipuzkoa operate their own system. Since January 2026, TicketBAI has been fully in force there for all businesses, regardless of size or sector. Bizkaia has extended the system with BATUZ, which also covers bookkeeping.

Verifactu does not apply in the Basque Country. Companies operating there must comply with TicketBAI instead. Navarra has its own rules as well, but without TicketBAI.

Exemption via SII

Companies that already use the Suministro Inmediato de Información (SII) real-time VAT reporting system, introduced in 2017, are exempt from Verifactu. SII is mandatory for businesses with annual turnover above EUR 6 million and transmits invoice data to AEAT almost in real time.

Solución Pública (SPFE)

The free public platform operated by AEAT will become the central repository of Spain’s e-invoicing system. Even if you use a private platform, you must send a UBL copy of each invoice to SPFE. No one is fully outside the system.

Status messages as a key driver

The 4-day deadline for status updates is more demanding than it looks. Recipients must send acceptance or rejection messages and report the actual payment date. Companies active in B2B business with Spain need to adapt internal approval workflows accordingly.

Hamburg logistics perspective

For Hamburg-based logistics providers with regular Spain lanes, the B2B mandate is becoming a strategic topic. EDIFACT remains allowed, which protects existing maritime EDI setups. A full format migration is not required, but adaptations of mappings and interfaces will be.

Frequently Asked Questions on E-Invoicing in Spain

Do I, as a German exporter, have to use Verifactu-compliant software?

No, not if you do not have a permanent establishment in Spain. Your German invoicing software can continue sending PDFs or EDI messages to Spanish customers.

What about the B2B e-invoicing mandate – do I need to send structured XML invoices?

Legally, the obligation applies to B2B transactions between entities established in Spain. Cross-border supplies from Germany are not directly in scope. However, Spanish customers will increasingly ask for structured formats to standardise their internal processes.

Can I use Peppol for Spain?

Yes, provided your Peppol provider supports the Spanish requirements. Peppol BIS in UBL syntax is explicitly recognised as valid under Royal Decree 238/2026.

What about Facturae and FACe?

Facturae remains the standard for B2G invoices to Spanish public authorities – this has been mandatory since 2015 and will not change. In B2B scenarios, Facturae continues to be allowed as one of four approved formats.

How is Spain different from Germany?

Germany is moving towards a single system with universal receiving obligations from 2025 and phased sending obligations from 2027/2028. Spain is introducing a dual approach: Verifactu as a software requirement and a separate B2B e-invoicing regime for invoice exchange. In addition, Spain mandates status messages, which Germany does not.

What are the penalties for non-compliance?

Verifactu infringements can lead to penalties of up to EUR 50,000 per year for users and up to EUR 150,000 per year for software providers. Sanctions for the B2B regime are based on Law 18/2022 “Crea y Crece”; further details will be specified in the upcoming Ministerial Order.

BESITEC’s Approach to Spain Projects

At BESITEC, we integrate Spanish requirements into your existing EDI infrastructure. Our focus is on direct ERP integration, similar to our established SAP EDI methodology.

Our approach:

• Conversion to Facturae from EDIFACT, SAP IDoc or XML
• Electronic signatures in line with Spanish requirements
• Direct connection to FACe (B2G) – already in productive use for years
• Preparation for the B2B mandate from 2027 using Peppol BIS / UBL
• One system to cover German e-invoicing mandates as well as Belgium, Poland and Spain

Whether fully automated from SAP or manually via web.invoice, your invoices will be delivered to Spanish recipients in the correct format.

Especially relevant for sectors with regular Spain business:

• Automotive (suppliers in Catalonia, Valencia, Basque Country)
• Mechanical engineering (industrial hubs in Madrid, Barcelona, Bilbao)
• Container logistics (Hamburg–Algeciras, Hamburg–Valencia, Hamburg–Barcelona)
• Retail and distribution (large Spanish retail chains)

Conclusion: Managing Spain Compliance Pragmatically

Spain is rolling out two e-invoicing systems in parallel – Verifactu from 2027 and the B2B mandate from 2027/2028. Both apply to entities established in Spain. German exporters without a permanent establishment are not directly in scope, but will increasingly need to support compatible formats.

Key takeaways:

• Two systems: Verifactu (anti-fraud) and B2B e-invoicing (exchange) run in parallel
• Timeline: Verifactu in January/July 2027 (fixed), B2B mandate expected from October 2027/2028
• Flexible formats: UBL, CII, EDIFACT, Facturae, Peppol BIS – all EN 16931-compliant
• Status messages: 4-day deadline for responses – a significant change compared to today
• Regional nuances: TicketBAI in the Basque Country, separate regime in Navarra

What you should do by the end of 2026:

1. Take stock: Do you have a Spanish subsidiary or permanent establishment? Which customers and suppliers are based in Spain?
2. Review processes: Which invoice formats and channels do you currently use (PDF, EDI, Peppol, Facturae)? Where are the media breaks?
3. Check systems: Is your ERP / EDI / invoicing software capable of supporting Verifactu and the B2B mandate, or can it be extended?
4. Define the project approach: Select a pilot entity or pilot customers and plan the go-live window (allow 3–6 months of implementation time depending on ERP complexity).

Companies with Spanish subsidiaries, regular suppliers or major industrial customers in Spain should start planning no later than Q3 2026. Depending on the complexity of your ERP landscape, the technical integration will typically take 3–6 months.

Sources: BOE-A-2023-24840 (Royal Decree 1007/2023), BOE-A-2026-7295 (Royal Decree 238/2026), AEAT information, as of April/May 2026.

This article does not constitute legal advice. All information is provided without guarantee and reflects the situation as of May 2026. For binding guidance, please consult your tax advisor or legal counsel.