E-invoicing · Verifactu
Verifactu vs mandatory e-invoicing: what binds the issuer and what falls on accounts payable
Verifactu regulates the software with which a company issues its invoices and only binds whoever invoices; mandatory e-invoicing regulates the format and the exchange of invoices between companies and also binds whoever receives them, who will have to report the rejection and the payment of each invoice. For an accounts payable department, Verifactu creates no new obligation; e-invoicing does, from 6 October 2027 if the company's volume of operations exceeds EUR 8 million and from 6 October 2028 if it does not.
Sources checked on 24 October 2026: Royal Decree 1007/2023 (Regulation on invoicing computer systems), Royal Decree-law 15/2025, the Ministry of Finance information note of 5 October 2026, Royal Decree 238/2026 and the Spanish Tax Agency calendar. Informational guide; it does not replace tax advice.
The two obligations, side by side
| Verifactu | B2B e-invoicing | |
|---|---|---|
| Rule | Royal Decree 1007/2023, Regulation on invoicing computer systems | Law 18/2022 and Royal Decree 238/2026, with Order HAC/1028/2026 |
| What it regulates | Invoicing computer systems: integrity, preservation, accessibility, legibility, traceability and unalterability of the records (art. 8.1) | The structured format of the invoice, the exchange channel and the invoice statuses (arts. 6, 7, 10 and 12) |
| Who it binds | Whoever issues invoices with a computer system. The recipient has no obligations: it may, voluntarily, provide the Spanish Tax Agency with the data in the invoice's QR code (art. 17.1) | Whoever issues and whoever receives: the recipient reports acceptance or rejection and payment to the issuer, and rejection or payment to the public solution |
| What the recipient sees | A QR code on the invoice and, if the issuer sends its records to the Spanish Tax Agency, the wording “VERI*FACTU” (art. 6.5 of the Invoicing Regulation, as worded by RD 1007/2023) | A structured message in UBL, CII, EDIFACT or Facturae; for twelve months, accompanied by a PDF if the issuer exceeds EUR 8 million |
| Dates | Before 1 January 2027 for Corporate Income Tax payers; before 1 July 2027 for everyone else. The Ministry of Finance has announced its postponement to October 2028, with no rule published yet | 6 October 2027 (volume of operations above EUR 8 million) and 6 October 2028 (everyone else); statuses for self-employed people at EUR 8 million or less, 6 October 2029 |
| Who is left out | Among others, those who keep their VAT record books through the Immediate Supply of Information (art. 3.3 of RD 1007/2023) | Transactions documented with a simplified invoice, except qualified ones (art. 4.1 of RD 238/2026), and other exclusions in the Royal Decree itself |
Why Verifactu barely touches a large company as an issuer
Article 3.3 of Royal Decree 1007/2023 excludes from Verifactu those who keep their VAT record books under article 62.6 of the VAT Regulation, that is, through the Immediate Supply of Information (SII) on the Spanish Tax Agency's electronic office. That article 62.6 applies to those who settle VAT monthly, and article 71.3 of the same Regulation places on monthly settlement, among others, anyone whose volume of operations exceeded EUR 6,010,121.04 the previous year and anyone applying the special regime for groups of entities.
The practical consequence: as a general rule, a company above the EUR 8 million threshold of e-invoicing is also in the SII and does not have to adapt its invoicing software to Verifactu. It is worth confirming this company by company with the tax adviser, because a group may have subsidiaries below the threshold.
What does reach that large company is Verifactu on its suppliers' side: suppliers that are not in the SII will issue invoices with a QR code. Receiving invoices with a QR code creates no obligations for the recipient.
Mandatory B2B e-invoicing in Spain changes the receiving side too. The guide for the company that receives the invoices explains what changes and when. Read the e-invoice reception guide
What each one means for accounts payable
| Accounts payable question | Verifactu | B2B e-invoicing |
|---|---|---|
| Does the way invoices reach me change? | No: they still arrive as PDF or paper, with a QR added | Yes: they arrive as a structured message through a platform or through the public solution |
| Do I have to report anything to the Spanish Tax Agency? | No. Providing the QR data is voluntary | Yes: the rejection and the full payment, with the due date |
| Is there a deadline? | No | Four calendar days, excluding Saturdays, Sundays and national public holidays, to report acceptance or rejection to the supplier and to report the payment; rejection before the public solution has no deadline of its own in the rule |
| Does it tell me whether the amount is right? | No: the QR identifies the invoice, it does not check that the price is the purchase order price | No: the format guarantees the structure, not that price and quantity match the purchase order and delivery note |
| Do I still need the purchase order and the delivery note? | Yes | Yes, and with a deadline to reject as well |
Neither of the two rules replaces purchasing control. Verifactu makes sure that the invoice being issued is recorded and cannot be altered; e-invoicing makes sure that the invoice travels in structured form and that its payment is reported. Neither checks that the invoice charges what was ordered and received. That line-by-line match is explained in matching invoice, purchase order and delivery note line by line.
The postponement of Verifactu to 2028: announced, not published
On 5 October 2026, the Ministry of Finance published an information note announcing its intention to postpone the outstanding obligations of Royal Decree 1007/2023 until October 2028, to make them coincide with mandatory e-invoicing for those who invoice EUR 8 million or less, and to then address an amendment to make the two rules converge. As of 24 October 2026 that postponement is not in the BOE: the dates in force are still those of Royal Decree-law 15/2025 (1 January 2027 and 1 July 2027). The Spanish Tax Agency's Verifactu page links the note as a “forecast”. The e-invoicing calendar (in Spanish) lists both dates and is updated when the rule changes.
What ininvoice does with each one
ininvoice works on the side of whoever receives the invoices. It has nothing to do with Verifactu as an issuer, because it does not issue invoices; nor does it read or verify the QR code on the invoices received. With e-invoicing, today it reads invoices as PDF, image, scan or photo, and direct reading of structured e-invoices is in development; the statuses are reported by the e-invoicing platform or the public solution. What ininvoice adds in both cases is what neither rule does: matching every line against the purchase order and the delivery note, holding duplicates and keeping the decision to approve or reject recorded with its date.
Frequently asked questions
Are Verifactu and e-invoicing the same thing?
No. Verifactu (Royal Decree 1007/2023) regulates the systems with which invoices are issued and binds whoever invoices. B2B e-invoicing (Law 18/2022 and Royal Decree 238/2026) regulates the format and the exchange between companies and also binds whoever receives.
Does Verifactu bind the recipient of the invoice?
No. Royal Decree 1007/2023 imposes no obligations on the recipient; its article 17.1 allows the recipient, voluntarily, to provide the Spanish Tax Agency with the data in the invoice's QR code.
Does a company in the SII have to comply with Verifactu?
Not as an issuer: article 3.3 of Royal Decree 1007/2023 excludes those who keep their VAT record books under article 62.6 of the VAT Regulation, which is the Immediate Supply of Information.
Has Verifactu been postponed to 2028?
The Ministry of Finance announced on 5 October 2026 its intention to postpone it until October 2028. As of 24 October 2026 it is not in the BOE; the dates in force are 1 January 2027 for Corporate Income Tax payers and 1 July 2027 for everyone else.
Which of the two affects accounts payable more?
B2B e-invoicing: it changes the format and the channel through which invoices arrive and requires the rejection and the payment to be reported within four days. Verifactu does not change the recipient's work.
Every invoice line, matched against its purchase order and delivery note
Today ininvoice reads supplier invoices in PDF, image or scanned form, line by line, and matches every line against its purchase order and delivery note; reading Facturae XML e-invoices is in development. Send me 3–5 supplier invoices and we will go through them together.
Request a demo with your own invoices