2026 likely new launch date for state-only or VERI*FACTU approved invoicing software may be used to prepare and issues invoices
Spain has sent to the European Commission new technical details in a Draft Order of its VERI*FACTU mandatory invoicing software proposals for all resident taxpayers. There are limited changes in this new draft
The EC and other member states will review this, and must return any amendment suggestions by 4 October 2024. Spain can then complete the Order. Originally, this had a launch date of July 2025. But this new EC-review step, like the separate Spanish B2B e-invoicing (Crea y Crece) resubmission, means January 2026 will be a more realistic launch target.
May 2024: Royal Decree on digital invoice creation
Spain has published the Royal Decree for the launch rules on invoices and their production electronically, including computerised invoicing. But it now appears that the planned launch for 1st July 2025 will be missed, and a launch early in 2026 is likely. The delay is due to a similar delay on mandatory e-invoicing.
This includes certified invoicing systems and voluntary submission of invoices to the Agencia Tributaria – sistemas y programas informáticos o electrónicos (‘SIF’). This applies to Spanish resident taxpayers – non-residents are exempt unless they have a VAT fixed establishment in Spain.
On 20 December 2023, the Agencia Tributaria issued technical specifications for the VERI*FACTU regime. This measure has been repeatedly delayed – the last launch date was for 1 July 2024 following a public consultation.
Taxpayers may also be deemed to be compliant when using the existing Spanish SII live reporting regime.
‘Verifiable invoicing systems’ or VERI*FACTU systems
Taxpayers will be able to use some limited approved invoicing systems from the tax authorities. Otherwise, any commercial product must include commitments to compliance with the new rules, including submission of invoices to the Agencia Tributaria. Such systems will be deemed ‘verifiable invoicing systems’ or VERI*FACTU systems
The new rules only apply to resident businesses. Non-residents without a permanent establishment are not included.
New transactional-level requirements
Taxpayers will be required to hold defined data set requirements for each transaction. These include:
- Current Spanish invoice disclosure obligations
- Unique and sequential digital hash identifier for the transaction
- Digital time stamp for the transaction
- Digital market indicating the ERP, invoicing or similar system that created the record
- QR Code which the customer may use to verify compliance
Any invoices not reported via VERI*FACTU must be separately digitally identified for audit purposes via a Qualified Electronic Signature.
Portugal certified invoicing systems includes similar requirements.
The previous Royal Decree sets minimum standards on accounting and invoicing technologies to prevent fraudulent invoices or manipulation of data. This covers technical specifications and rules to safeguard the creation, integrity, auditability and security of invoices and supporting documents. This includes minimum requirements for producers of systems and accounting software to produce invoices in standard formats.
- Key features of the new regime will include:
- Digital fingerprints or ‘hash’ on records
- Electronic signatures when not submitting invoices directly to the tax office
- ID code for the software used to produce the invoice
- Time stamping electronically
- Digital referencing on credit notes and replacement invoices
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