B2B E-Invoicing vs VeriFactu in Spain: Two Different Obligations You Must Not Confuse
B2B e-invoicing and VeriFactu are not the same thing. They are two separate regulations with two different objectives, two different timelines and two different types of obligations. Yet confusion between them is extremely common — even among tax advisors and accounting firms. This guide definitively clarifies what each one is, who it affects and how they relate to each other.
Why are these two obligations confused?
Both involve invoicing. Both come from the Spanish tax and regulatory environment. And both are coming into force in the near future. That is enough for many businesses and their advisors to treat them as a single requirement.
But they are completely separate legal frameworks. Position Paper No. 3/2026 by Economistas Contables EC-CGE (Consejo General de Economistas de España) makes this explicit: it is necessary to distinguish mandatory B2B e-invoicing from the fiscal reporting obligations known as VeriFactu. While e-invoicing focuses on commercial exchange, VeriFactu has different objectives defined by the AEAT.
Let us look at each one separately.
What is B2B e-invoicing? (RD 238/2026)
The regulation and its origin
B2B e-invoicing is governed by Royal Decree 238/2026, which implements the Spanish "Ley Crea y Crece" (Create and Grow Act, Law 18/2022). Its objective is to digitise the Spanish productive sector and reduce late commercial payments by making it mandatory to issue and receive invoices in structured electronic format.
Who does it affect?
All companies and self-employed professionals who conduct commercial transactions between themselves (B2B) and have their registered address, permanent establishment or habitual residence in Spain. It does not affect transactions with end consumers (B2C).
What does it require?
- Issuing and receiving invoices in structured formats: Facturae, UBL or CII. Simple PDFs and paper invoices are no longer valid for B2B transactions.
- Using platforms that are interoperable with each other and with the AEAT's public solution.
- Reporting invoice status (issuance, acceptance, rejection, payment) to the AEAT within a maximum of 4 calendar days.
When does it come into force?
The deadlines have not started yet. Everything depends on the Ministerial Order from the Ministry of Finance governing the public invoicing solution, which is currently in a public consultation process (deadline: 8 May 2026). Once that Order is published:
- 12 months: companies with annual turnover above €8 million.
- 24 months: all other companies and professionals.
- 36 months: freelancers and income-attribution entities with turnover at or below €8 million.
For a full breakdown of these deadlines, see our article on the real deadlines of RD 238/2026.
What is VeriFactu? (RD 1007/2023)
The regulation and its origin
VeriFactu is governed by Royal Decree 1007/2023, which implements Article 29.2.j of Spain's General Tax Act. Its objective is fundamentally different from that of B2B e-invoicing: to guarantee the integrity and immutability of invoicing records generated by invoicing software, preventing tax fraud through the manipulation of accounting data.
Who does it affect?
All business owners and professionals who use invoicing software in their activity — regardless of whether their customers are businesses or private individuals. This is not an obligation about exchanging invoices between parties: it is an obligation concerning the software system itself that generates the invoices.
What does it require?
The invoicing software must:
- Generate an invoicing record with a digital fingerprint (chained hash) for each invoice, ensuring it has not been altered.
- Include on each invoice a QR code and the label "Verifactu" when records are submitted to the AEAT, or "Sistema Verifactu" otherwise.
- Optionally (though recommended): submit invoicing records to the AEAT in real time or on a deferred basis.
The obligation falls not on the business itself, but on the invoicing software provider, which must certify that its product meets the technical requirements of RD 1007/2023.
When does it come into force?
- 1 January 2027: for commercial companies and other legal persons.
- 1 July 2026 (provisional date): for natural persons operating as business owners or professionals.
These dates are independent of the Ministerial Order for B2B e-invoicing.
The definitive comparison table: B2B vs VeriFactu at a glance
| B2B E-Invoicing (RD 238/2026) | VeriFactu (RD 1007/2023) | |
|---|---|---|
| Objective | Digitise commercial exchange between businesses | Guarantee the integrity of invoicing software |
| Regulation | RD 238/2026 (Ley Crea y Crece) | RD 1007/2023 (General Tax Act) |
| Transactions | B2B only (business to business or professional) | All: B2B and B2C |
| Obligation on | The exchange of invoices between parties | The software that generates the invoices |
| Required formats | Facturae, UBL, CII (structured) | Chained hash + QR code on the invoice |
| Report to the AEAT | Invoice status (payment, acceptance…) | Invoicing records (optional or automatic) |
| Entry into force — companies | 12 months from Ministerial Order (no date yet) | 1 January 2027 |
| Entry into force — freelancers | 36 months from Ministerial Order | 1 July 2026 (provisional) |
How do they relate? They can overlap, but they do not replace each other
A company can be subject to both regulations at the same time. For example, a company that invoices other businesses must:
- Use VeriFactu-compliant software from 1 January 2027.
- Issue and receive invoices in structured electronic format under RD 238/2026 once its deadlines come into force.
Complying with one does not mean complying with the other. They are independent layers of obligation covering different aspects of the invoicing process.
What does InvoSeal cover?
InvoSeal is built to deliver compliance with VeriFactu (RD 1007/2023): it generates invoicing records with a chained digital fingerprint, includes the QR code and the required label, and enables the submission of records to the AEAT.
For B2B e-invoicing under RD 238/2026, the technical platform and interoperability requirements will be defined in detail by the pending Ministerial Order. InvoSeal is closely monitoring these developments to provide full coverage once the deadlines come into force.
You can find our technical documentation on VeriFactu in our verifiable invoicing system documentation.
Frequently asked questions: B2B vs VeriFactu
If I comply with VeriFactu, am I ready for B2B e-invoicing?
No. VeriFactu governs the integrity of invoicing software; B2B e-invoicing governs the exchange of invoices between businesses in structured format. They are obligations covering different aspects of the process. Complying with one does not exempt you from the other.
Does VeriFactu affect freelancers who only invoice private individuals?
Yes. VeriFactu applies to all business owners and professionals who use invoicing software, regardless of whether their customers are businesses or private individuals. B2B e-invoicing, by contrast, only applies when the recipient is another business owner or professional.
Does invoicing software need to change for both regulations?
Generally yes, but for different reasons. For VeriFactu, the software must be able to generate records with chained hash values and a QR code. For B2B e-invoicing, it must be able to issue and receive invoices in structured formats (Facturae, UBL, CII) and interact with interoperable platforms.
Which of the two obligations affects me first?
It depends on your situation. VeriFactu has fixed dates: 1 July 2026 for freelancers and 1 January 2027 for companies. B2B e-invoicing has no start date yet because it depends on the pending Ministerial Order. In practice, VeriFactu will arrive first for the vast majority of businesses.
What if my advisor says they are the same thing?
It is a common mistake. The distinction is explicitly set out in Position Paper No. 3/2026 by Economistas Contables EC-CGE, one of Spain's leading technical reference bodies on accounting matters. It is worth clarifying this before planning your company's technological adaptation.
Conclusion: two regulations, one dual adaptation strategy
Confusing VeriFactu and B2B e-invoicing is not a minor detail: it can lead companies to believe they are compliant when they are not, or to invest in solutions that only address one of the two obligations.
The first step is to understand the difference. The second is to verify what software you use, whether it is VeriFactu-compliant, and what steps you need to take to be ready for B2B e-invoicing as well, once its deadlines come into force.
If you have questions, consult your advisor or refer to the official documentation of RD 238/2026, RD 1007/2023 and EC-CGE Position Paper No. 3/2026.