Spain’s tax reporting regulations are changing with an increasing shift to e-invoicing and real-time reporting to the tax authorities. Here’s what you need to know about the existing legislation such as SII and Ticket BAI and the new tax reporting regulations such as the Veri*factu regulation and the upcoming Crea y Crece law. We’ll walk you through these regulations, what they mean for businesses in Spain and what the difference is between them.
Let’s first take a look at the upcoming regulations that most people are talking about; the Veri*factu regulation and the upcoming Crea y Crece law.
The Veri*factu regulation
In December 2023, the Spanish government approved a decree outlining the technical requirements for computerised invoicing systems. This Royal Decree 1007/2023, or legal regulation, is fondly known as the Veri*factu regulation.
The regulation, which comes into effect in July 2025, sets out a standardised way of creating billing records electronically. It opens the door to ensuring that all businesses send real-time invoicing information to the tax authorities instead of periodic VAT returns.
When it comes into effect, every business in Spain will have to use an invoicing system that complies with these requirements. The only exception are the businesses that are already sending real-time information to the authorities under another system known as SII (Suministro Inmediato de Información). Every business turning over more than six million Euros is already following SII.
Standardised records required in the Veri*factu regulation
Every company will be mandated to create a record for every customer invoice, either prior to or during issuance. Termed "registros de facturación de alta" in Spanish, the regulation specifies a standardised format, structure, and technical criteria. This ensures traceability for each entry and prevents alterations without leaving a system mark.
Each invoice registry must include the following elements:
All standard invoice fields, such as supplier and buyer tax data, issue date, and line items. All currency fields must be in Euro;
A "digital fingerprint" or "hash" that links consecutive registries
A qualified electronic signature (QES) for invoices not submitted to the Spanish tax authorities (AEAT). In other words, a QES is not required for invoices reported via Veri*factu software
An ID identifying the system used to produce the invoice
A digital timestamp
If associated with a corrective invoice, a digital reference to it
Other important characteristics of Veri*factu
There are three other important points that need to be known also about these new regulations.
1. QR codes on invoices
Similar to TicketBAI (see below), Veri*factu mandates the inclusion of a QR code in both standard and simplified invoices.
Additionally, if the invoice has been real-time reported to the Spanish tax authorities (AEAT), the wording “Factura verificable en la sede electrónica de la AEAT” or “VeriI*Factu” must be included. This informs customers that they can scan the QR code to check the invoice's validity with the tax authority.
2. SIF registration
A computerised billing system in Spain is known as a SIF (Sistemas Informaticos de Faturacion).
The SIF developer is required to declare and register its software with AEAT in writing. Declaration details must be visible in the computer system for each version, at the time of purchase, and retained throughout the prescribed period of tax obligations.
This declaration may be requested by the client or by AEAT from the person or entity that produces or markets the SIF.
More specifications are being set for SIF providers and when set, SIF providers will have nine months to be ready from the time the final specifications are set.
3. Verification by the AEAT
The regulation empowers AEAT to appear at the place where the computer system is located or used and demand complete and immediate access to the data contained therein, as well as proceed to download, dump, consult or copy it.
The Crea y Crece law
The new Crea y Crece law is different from Veri*factu. It’s not yet in place and the exact timing of when it will take effect is not yet certain, but it’s coming. The big change with this law compared with previous legislation is that it will require that all businesses and self-employed individuals to send electronic invoices.
The notion behind this is to make it easier for entrepreneurs to get paid on time when the invoicing process is digitised.
What are the main differences between Veri*factu and Crea y Crece?
Veri*factu mainly introduces requirements for information to be stored by invoicing software and ways to store it. It does not regulate the format or the distribution channel for e-invoice exchange between the trading partners.
Crea y Crece will require the use of specific electronic formats (not PDF) and channels for business exchange.
Crea y Crece (Invoice exchange)
Crea y Crece will be implemented in a gradual manner, although the timelines are not yet set in stone. The gradual roll-out is as follows:
Invoice issuance & statuses implementation timeline
| Obligation | Taxpayers in scope | Deadline |
|---|---|---|
Sending and Receiving e-invoices + invoice statuses | Legal entities and sole traders with annual turnover > EUR 8 million | 1 year |
Sending and Receiving e-invoices + invoice statuses | Legal entities with annual turnover < EUR 8 million | 2 years |
Sending and Receiving e-invoices | Sole traders with annual turnover < EUR 8 million | 2 years |
Invoice statuses | Sole traders with annual turnover < EUR 8 million | 3 years |
E-invoice statuses for Crea y Crece
The buyer will be required to report to the seller the following information within four calendar days:
Whether they accept or reject the invoice and the date on which they do
That they have paid the invoice in full and the date on which it was paid
Buyers can also voluntarily report partial acceptance or rejection of the invoice, partial invoice payment and information about the third-party involvement in the invoice payment.
Interconnection between platforms
It works like this. When a sending platform seeks to establish a connection with a new platform, a request is sent to the receiving platform, and the receiving platform must make sure the interconnection happens within a month. The platform receiving the signal must fulfil the following requirements:
Provide technical documentation
Enable a testing environment
Dedicate the necessary resources
Not charge any money for it
The two regulations, Veri*factu and Crea y Crece, will co-exist in the future so, companies in Spain must soon comply with both regulations.
However, to date it remains unclear whether businesses with an annual turnover between EUR 6 and 8 million are required to comply with both SII and Crea y Crece reporting.
Exceptions - SII and TicketBAI
There are exceptions to the regulations above and they are the ones who are already using a system that requires the same or similar.
As mentioned above, SII is the system already in place for businesses turning over more than 6 million Euros a year.
Another system in place is Ticket BAI, which is in place in the Basque region of Spain. Ticket BAI is similar to the Veri*factu regulations, which is why those using it are exempt.
The other exception to the upcoming regulations are those companies exempt from issuing invoices.
Staying compliant: E-invoicing in Spain with Pagero
These changes mark a pivotal advancement in Spain's e-invoicing landscape and will lead to increased transparency for the tax authorities.
At Pagero, we’re closely following the regulatory landscape in Spain and ensuring seamless compliance with all mandates. From making buying and selling easier to providing ongoing support and updates, Pagero stands by its commitment to empowering businesses with efficient and compliant invoicing processes.
Stay compliant with Pagero
Topics:
Stay in the loop with our newsletter
