Verifactu and SII: Understanding Spain’s Invoicing E-Reporting Systems

From 2026, Spain will implement new rules on electronic invoicing through a system known as Verifactu, targeting businesses not currently using the . This article explains how these systems differ, who is affected, and what obligations apply.

What Is the SII System?

The SII (Suministro Inmediato de Información), or Immediate Supply of Information, has been mandatory in Spain since 2017 for certain taxpayers, including:

• Companies with annual turnover exceeding €6 million
• Businesses under the Monthly VAT Refund Scheme (REDEME)
• Entities applying the VAT Grouping Regime

These companies submit invoice data in real time to the Spanish Tax Agency (AEAT) in XML format, allowing near-instant access and validation by the authorities. The SII system covers both issued and received invoices, with a submission deadline of four calendar days.

What Is Verifactu?

Verifactu is part of a broader legal framework known as SIF (Sistemas Informáticos de Facturación), or Invoicing Information Systems, introduced under Spain’s new e-invoicing regulations.

From 1 January 2026, businesses not using SII will need to comply with Verifactu or an alternative SIF-compliant solution. These systems will be mandatory for issuing invoices and storing invoice data securely.

Key goals include:

• Preventing invoice fraud
• Ensuring traceability and transparency
• Improving real-time tax oversight

Are SII Users Affected by Verifactu?

For the most part, no.

Companies already using SII are exempt from Verifactu and other SIF-related requirements. Since these businesses already submit detailed invoice data in real time, Spanish authorities consider further obligations unnecessary.

Why? SII users already:

1. Submit XML files with key invoice details
2. Pass data validations by the AEAT
3. Are frequently audited, ensuring data accuracy and transparency.

Are There Any Exceptions?

Yes — in specific cases:

• Self-Billed Invoices (Autofacturas): These are invoices that a company issues to itself (typically for cross-border VAT reasons). SII users already report these in their issued invoice records, so no duplication is required.
• Third-Party Issued Invoices (Non-Self-Billed): If a third party issues invoices on behalf of the supplier, the rules differ:
  • If legally required, SII companies remain exempt from Verifactu
  • If based on a private agreement (not legally mandated), Verifactu may apply.

To clarify this, Spain passed Royal Decree 254/2025, which explicitly excludes self-billed and legally mandated third-party invoices from the Verifactu obligation for SII users.

What About Voluntary SII Users?

Companies that voluntarily opt into the SII system also benefit from the same exemptions from Verifactu and SIF compliance.

Voluntary SII users can continue filing VAT quarterly (they are not forced into monthly filing) and can opt in before the start of the tax period they wish to begin using SII.

What are the main differences between SII and SIFs obligations?

• In both obligations, it is necessary to create an XML file with the main content of the invoice. This file in both cases essentially contains the same information, with two differences:
  • Under SII, simplified invoices or tickets may be recorded via a daily summary entry, whereas under SIFs every single simplified invoice must be logged individually.
  • In the SIFs‑XML, it is also necessary to include information on the security hash (which ensures the chain with previous invoices), identification of the SIFs and their developer or marketing company, and the exact date and time (day, hour, minute, second) of the invoice issuance. None of that is required under SII.
• Deadline for submission: Under SII, the maximum period is 4 days. In contrast, under the SIFs obligation, if the Verifactu modality is chosen, the deadline is 60 seconds (or, in the non‑Verifactu modality, the invoice may be retained until the Tax Agency requests it).
• Scope of obligation (which invoices are covered): SII requires information on both invoices issued and received, whereas the SIFs obligations only affect invoices issued.
• Content of the invoice: Under the SIFs regime, it is required to include a QR code on invoices, and, where applicable, the word “Verifactu” when that modality is chosen.

Verifactu or SII: Marosa Can Help You!

• If your company is already complying with Spain’s SII regime, no action is required regarding Verifactu. The only exception could be in case your company issues invoices on behalf of a third party.
• If not, and you issue invoices in Spain, you will likely need to adopt Verifactu or another SIF-compliant solution from 1 January 2026 or 1 July 2026.
  • The choice between Verifactu and non-Verifactu modalities depends on whether you want to submit invoice data immediately (within 60 seconds) or wait until requested by the AEAT.
  • Voluntary adoption of the SII obligation is an option in case you want to be out of the Verifactu scope.

If you need tailored advice or support with implementing SII or Verifactu, our VAT experts at Marosa can help ensure your compliance with Spain’s evolving e-regulations.