Regulatory updates - Spain

Verifactu is Spain's new real-time invoice reporting system mandated by the Agencia Estatal de Administración Tributaria (AEAT) as part of Law 11/2021, which aims to combat tax fraud through enhanced invoice traceability. The system requires invoices to be transmitted to AEAT in real time, with software providers meeting strict technical and legal standards.

Pagero completed the Veri*factu certification process by submitting a formal self-declaration to Spain’s tax authority (AEAT). This confirmed that its invoicing system meets all legal and technical requirements. The declaration is now publicly listed, making Pagero an officially recognized Verifactu service provider.

With this certification, Pagero can help Spanish companies:

• Transmit invoices to AEAT in real time
• Ensure compliance with the Anti-Fraud Law
• Avoid non-compliance penalties
• Benefit from streamlined, secure invoicing processes

The Verifactu regulation follows a phased implementation:

• July 29, 2025: Deadline for software producers and vendors
• January 1, 2026: Corporate taxpayers must adopt compliant systems
• July 1, 2026: All other taxpayers must comply

Royal Decree 254/2025, published in the BOE (Official State Gazette) on April 2nd, modifies Royal Decree 1007/2023 and establishes the following new deadlines for taxpayer compliance:

• Corporate Taxpayers: The compliance deadline has been extended to January 1, 2026, a six-month delay from the original date of July 1, 2025.
• All Other Taxpayers: The compliance deadline is now July 1, 2026.
• Software Producers and vendors: The compliance deadline remains the same, July 29, 2025.

In contrast, this extension also affects software producers and vendors covered by multi-year maintenance contracts in effect before the 9-month period. Their deadline has been extended from July 1, 2025, to January 1, 2026, to ensure their products meet Veri*factu requirements.

The delay is attributed to the complex process of drafting and approving the regulation and the late publication of Ministerial Order HAC/1177/2024 on October 17, 2024. This order details the technical, functional, and content specifications outlined in Royal Decree 1007/2023.

Taxpayers already utilizing the Immediate Information Supply (SII) system for VAT record-keeping are exempt from Veri*factu requirements, as their existing systems are considered to provide sufficient information and guarantees. This exemption also applies to invoices issued for operations documented by the recipient or a third party due to mandatory regulations.

The Veri*factu regulation aims to standardize invoicing processes and ensure greater transparency in business transactions. The deadline extensions are intended to provide businesses and software providers with more time to adapt to the new requirements.

Among several proposed changes, the most significant is the adoption of the UBL (Universal Business Language) format for the public e-invoicing solution, aligning with the EU's VAT in the Digital Age (ViDA) directive and replacing the previous Facturae syntax.

The public consultation will also analyze other proposed changes:

• The draft also clarifies payment details for credit and debit notes and establishes specific methods for calculating payment terms, including start and end dates;
• Invoices created on the public platform will be VERI*FACTU compliant;
• Regulations around 'true copy' for private networks have also been updated.

While the regulations are taking shape, the final implementation date remains uncertain. The mandate will not take effect until at least one year after the ministerial order's approval for taxpayers with over 8 million euros in operations the previous year. For all others, the decree takes effect two years after approval, but only if an EU regulation exemption is obtained or is no longer required.

Technical specifications are still pending and will also be subject to public consultation. Businesses should monitor further announcements regarding the official implementation timeline.