Verifactu or electronic invoicing: the difference between two obligations everyone mixes up

Verifactu and electronic invoicing: the difference in two sentences

Verifactu regulates the program you issue invoices with. Article 1 of Royal Decree 1007/2023 puts it this way: it sets the requirements for "any computer system and program" that supports invoicing, to guarantee the "integrity, retention, accessibility, legibility, traceability and inalterability of the invoicing records". Its aim is that no invoice can be deleted or altered without leaving a trace.

B2B electronic invoicing regulates the invoice itself and its journey: a structured, machine-readable file that goes from your system to that of your business customer, who replies saying whether it accepts it and when it will pay. The obligation arises from article 12 of Law 18/2022, on the creation and growth of companies (Crea y Crece), which rewrites article 2 bis of Law 56/2007, and is developed by Royal Decree 238/2026. Its declared aim is late payment, not VAT.

Put briefly: Verifactu looks towards the tax authority; electronic invoicing, towards your customer.

What Verifactu requires and from whom

A program adapted to Verifactu generates, with each invoice, a registro de facturación (invoicing record) chained to the previous one by a hash, and prints a QR code that allows it to be checked against the AEAT (the Spanish tax agency). It can work in VERI*FACTU mode, sending each record to the AEAT as you invoice, or without sending, signing each record. All of this is explained in the guide on what is Verifactu.

Three traits that set it apart from electronic invoicing:

• It reaches all your invoices issued with a computer system, including those to private individuals and tickets (simplified invoices), under article 1.2 of the regulation.
• It binds almost everyone. Article 3 includes companies, autónomos with an economic activity, non-residents with a permanent establishment and income-attribution entities that invoice with a program, even if they only use it for part of their activity. Excluded are those who keep their books through the SII, as Verifactu and SII explains, entities fully exempt from Corporate Income Tax (article 9.1 of Law 27/2014, according to article 3.1.a of the regulation) and those with their tax domicile in the Basque Country or Navarre.
• It has a fixed date. Under Royal Decree-law 15/2025, companies before 1 January 2027 and everyone else, autónomos included, before 1 July 2027. The history of the postponements is in the Verifactu postponement.

Verifactu requires no special format and does not require the customer to receive anything different: you can deliver the invoice on paper or as a PDF, as long as it carries its QR.

What B2B electronic invoicing requires and from whom

Mandatory electronic invoicing has three verbs: issue, send and receive electronic invoices in dealings with other businesses and professionals. And it adds a fourth piece: reporting the invoice statuses, that is, whether you accept or reject it and when you pay it.

• Format: a structured message in line with the European EN16931 model, in UBL, CII, EDIFACT or Facturae (article 7 of RD 238/2026). A PDF does not qualify, even if signed.
• Channel: a private exchange platform or the free public solution of the AEAT.
• Scope: only invoices between businesses and professionals with a seat, establishment or domicile in Spain. Those to private individuals and to foreign customers without an establishment here are outside.

Since when? The regulation already exists, but it counts the deadlines from the entry into force of a ministerial order from the Ministry of Finance, with one group for large companies and a later one for the rest. We do not repeat those dates here because they depend on that order: the current status and the count of deadlines are in the guide on mandatory electronic invoicing, which is updated when there is news.

Comparison table: Verifactu vs electronic invoicing

The Verifactu fine is fixed and set by article 201 bis of the Ley General Tributaria; the software manufacturer is exposed to 150,000 euros per year and type of system. The electronic invoicing penalty is administrative, not tax-related, and is imposed by the Secretariat of State for Digitalisation, as detailed in the guide on mandatory electronic invoicing.

Five common mix-ups

1. "If my invoice has a QR, it is already electronic". No. The QR belongs to Verifactu and lets the tax authority check it. A PDF invoice with a QR meets Verifactu, but it is not a B2B electronic invoice, because it is not a structured file.
2. "If I already invoice the public administration in Facturae, I am in Verifactu". No. Facturae and FACe are the electronic invoicing to the public sector of Law 25/2013. It is one of the formats accepted for B2B, but it has nothing to do with the Verifactu chain of records.
3. "I am in the SII, so I escape both". Only Verifactu. The electronic invoicing regulation does not exclude those who keep their books through the SII, as the guide on mandatory electronic invoicing records.
4. "There is software approved by the AEAT for both". For Verifactu there is no approval: there is the declaración responsable (responsible declaration) of the manufacturer (article 15 of Order HAC/1177/2024). And for B2B electronic invoicing, nobody can be approved for a public solution whose order has not yet been published.
5. "The VAT I pay changes". Neither touches the VAT you charge or when it becomes chargeable. You keep filing your modelo 303 (the quarterly VAT return) the same way; what changes is how invoices are generated and travel.

How they fit together: they add up, they do not replace each other

You will not choose between one and the other. The guide on mandatory electronic invoicing records a fact that makes it clear: RD 238/2026 defines mandatory electronic invoicing as that produced by systems "adapted to article 29.2.j) of the Ley General Tributaria", which is precisely the legal basis of Verifactu. In other words, electronic invoicing rests on a Verifactu program.

In practice, every invoice you issue once both obligations reach you will have two layers:

• Verifactu layer: the chained record with a hash and the QR, for the tax authority. It goes on all your invoices.
• Electronic invoicing layer: the structured file, its sending and your customer's reply. Only on invoices to businesses and professionals with a seat in Spain.

If you sell mostly to private individuals, the second layer will hardly affect you when issuing, but it will when receiving: your suppliers' invoices will arrive as electronic invoices and you will have to accept them and report their payment. The mandatory content of each invoice does not change; it is still what your first invoice explains.

The practical answer: an autónomo needs both, in this order

1. First, Verifactu. It is the only one with a firm date. If you are an autónomo, your invoicing program must be adapted before 1 July 2027; if you have an SL, before 1 January 2027. The step-by-step plan is in Verifactu for autónomos. If you invoice with an Excel sheet or a Word file that also generates your books or your accounts, that is the urgent change; if you only use it to fill in and print, it is not an invoicing system according to the AEAT. The guide on Verifactu with Excel and Word (Spanish only) gives the detail.
2. When choosing a program, ask about both. Ask for the Verifactu responsible declaration and ask whether the program generates a structured format (for example Facturae) and how it plans to connect to the public solution once the order is published. If you want something minimal and free, the AEAT app meets Verifactu, but only invoices.
3. Then, electronic invoicing. When the ministerial order starts the calendar, you will have a period to adapt according to your group. Meanwhile, there is nothing to hire or file.
4. From now on, what works for both. A series of invoices without gaps, the tax IDs (NIF) of your business customers verified, expenses booked with their invoice and collections and payments reconciled with the bank.

With that order you avoid the costliest mistake: reaching 2027 waiting for electronic invoicing and invoicing with a system not adapted to Verifactu, which is what is penalised with 50,000 euros per year.

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