SIF, VeriFactu and B2B E-Invoicing: Spain's Three Major Invoicing Changes Explained
Spain is undergoing three simultaneous regulatory changes in invoicing that affect every business and freelancer. The problem is that many confuse them, mix them up or treat them as one. They are not. The SIF (Invoicing Computer System), VeriFactu and B2B e-invoicing are three distinct concepts, born from three different regulations, with three different objectives and three different timelines. This guide explains each one clearly, with their real deadlines and key differences.
Why distinguishing the three matters
Confusing these three concepts has practical consequences: businesses that believe they are compliant when they are not, advisors planning adaptation on a wrong basis, and software providers selling compliance with one regulation when the client also needs to comply with another.
All three changes will coexist. But they apply independently, covering different aspects of the invoicing process. Let us look at each one.
1. What is a SIF (Sistema Informático de Facturación — Invoicing Computer System)?
The official definition
A SIF is, according to the AEAT's definition, the set of hardware and software used to issue invoices that accepts invoicing data input by any method, stores that information and processes it to generate derived documents (standard and simplified invoices).
In practical terms: if your business uses any computer programme to issue invoices — whether an ERP, management software, a point-of-sale system or even a spreadsheet with formulas that allow alterations — that system is a SIF.
The regulation governing it
The SIF is governed by Royal Decree 1007/2023 (RRSIF), which sets out the technical requirements these systems must meet. The main objective is to eliminate so-called "dual-use software": programmes that allow businesses to conceal sales, delete invoices or manipulate accounting records without leaving a trace.
To comply with the RRSIF, a SIF must:
- Generate an invoicing record (RF) for each invoice issued, with a digital fingerprint (hash) chained to the previous record — making any subsequent alteration detectable.
- Include on each invoice a tax QR code with verifiable information.
- Guarantee the integrity, conservation, accessibility, legibility, traceability and immutability of the records.
- The software producer must issue a responsible declaration certifying that their system meets the RRSIF requirements.
Who does it affect?
All business owners and professionals established in Spain who use a computer system to issue invoices — to both businesses and private individuals. Also producers and distributors of invoicing software.
Excluded are those who invoice manually (without software), contributors to the SII (Immediate Information Supply system) and certain special tax regimes.
Deadlines
- Software producers and distributors: adapted since 29 July 2025 (already in force).
- Corporate Income Tax contributors (companies): SIF adapted before 1 January 2027.
- Freelancers, IRPF contributors and other obligated parties: SIF adapted before 1 July 2027.
2. What is VeriFactu?
The official definition
VeriFactu (also written VERI*FACTU) is a compliance mode of the RRSIF — not an independent regulation. It is the option in which the SIF, in addition to generating invoicing records with chained hash, transmits them in real time to the AEAT's electronic headquarters at the moment each invoice is issued.
In other words: a SIF that complies with the RRSIF can operate in two modes:
- VeriFactu mode: transmits records to the AEAT automatically. The invoice includes the label "Factura verificable en la sede electrónica de la AEAT" (Invoice verifiable at the AEAT electronic headquarters) or VERI*FACTU.
- Non-VeriFactu mode (non-verifiable system): stores records locally with all the required technical guarantees, but does not transmit them to the AEAT automatically. The invoice includes the label "Sistema Verifactu".
Is VeriFactu mode mandatory?
Not necessarily. The regulation requires that the SIF has the technical capacity to transmit records to the AEAT, but actual real-time transmission is an option — highly recommended as it simplifies compliance and reduces storage obligations. Non-VeriFactu mode is also valid if the system meets all the RRSIF integrity requirements.
InvoSeal operates in Non-VeriFactu mode: it generates all records with chained hash, QR code and the required integrity guarantees under the RRSIF, without automatic transmission to the AEAT. This is the mode chosen by those who want full control over their records before any submission.
Objective
The objective of VeriFactu (and the RRSIF in general) is to eliminate tax fraud derived from dual-use software. It does not modify the substantive invoicing obligations: it does not change who must invoice, what an invoice must contain or when it must be issued.
3. What is B2B E-Invoicing? (RD 238/2026)
The definition
B2B e-invoicing is the obligation to issue and receive invoices in structured electronic format (Facturae, UBL or CII) in all commercial transactions between businesses and professionals. It is governed by Royal Decree 238/2026, which implements the Ley Crea y Crece (Create and Grow Act, Law 18/2022).
Its objective is completely different from that of the SIF and VeriFactu: it is not about controlling the integrity of the software, but about digitising commercial exchange between businesses and combating late payment through payment traceability.
Who does it affect?
All business owners and professionals carrying out B2B operations (between businesses or professionals) with a registered address, permanent establishment or habitual residence in Spain. It does not affect sales to end consumers (B2C).
What does it require?
- Issuing and receiving invoices exclusively in structured formats: Facturae, UBL or CII. Simple PDFs and paper are no longer valid for B2B transactions.
- Using platforms that are interoperable with each other and with the AEAT's free public solution.
- Reporting invoice status (acceptance, rejection, payment) to the AEAT within a maximum of 4 calendar days.
Deadlines
The deadlines have not yet started. Everything depends on the Ministerial Order from the Ministry of Finance governing the public invoicing solution (currently in a public consultation process with a deadline of 8 May 2026). Once published:
- 12 months: 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.
See the full breakdown in our article on the real deadlines of RD 238/2026.
The definitive table: SIF vs VeriFactu vs B2B E-Invoicing
| SIF (RD 1007/2023) | VeriFactu (RRSIF mode) | B2B E-Invoicing (RD 238/2026) | |
|---|---|---|---|
| What it is | The computer system that issues invoices | SIF mode with real-time transmission to the AEAT | Obligation to issue invoices in structured format |
| Objective | Eliminate dual-use software / tax fraud | Automatic submission of records to the AEAT | Digitise B2B exchange and combat late payment |
| Regulation | RD 1007/2023 (RRSIF) | RD 1007/2023 (optional/voluntary mode) | RD 238/2026 (Ley Crea y Crece) |
| Affects | All who use software to invoice | Those opting for automatic AEAT transmission | Only B2B transactions between businesses |
| Transactions | B2B and B2C | B2B and B2C | B2B only |
| Invoice format | Any (the regulation governs the system, not the format) | Any (same) | Structured mandatory: Facturae, UBL, CII |
| Deadline — companies | Before 1 January 2027 | Same | 12 months from Ministerial Order (no date yet) |
| Deadline — freelancers | Before 1 July 2027 | Same | 36 months from Ministerial Order |
| Who certifies | Software producer (responsible declaration) | The system itself (transmits to AEAT) | Exchange platforms |
How they overlap: a practical example
Imagine a limited company that sells office supplies to other businesses. From 2027 it must:
-
Use a RRSIF-compliant SIF: its invoicing software must generate records with chained hash and QR code. It can do so in VeriFactu mode (transmitting to the AEAT) or in Non-VeriFactu mode (storing locally with all required guarantees).
-
Issue invoices to its business customers in structured format (Facturae, UBL or CII) through an interoperable platform, in accordance with RD 238/2026, once its deadlines come into force.
These are two distinct obligations covering two distinct aspects of the same invoicing process. Complying with one does not exempt from the other.
What InvoSeal covers
InvoSeal delivers compliance with the RRSIF (RD 1007/2023) in Non-VeriFactu mode: it generates invoicing records with chained hash, includes the regulatory QR code and guarantees the integrity and immutability of records in accordance with the Royal Decree's technical requirements.
For B2B e-invoicing under RD 238/2026, the platform and interoperability requirements will be defined by the pending Ministerial Order. InvoSeal is closely following these developments to offer full coverage when the deadlines come into force.
See our technical documentation on the verifiable invoicing system for details on how InvoSeal implements the RRSIF requirements.
Frequently asked questions: SIF, VeriFactu and B2B e-invoicing
Is VeriFactu mode mandatory or can I use Non-VeriFactu mode?
Both modes are valid. The regulation requires that the SIF has the technical capacity to transmit records, but does not mandate VeriFactu mode. Non-VeriFactu mode complies with the RRSIF if the system generates records with chained hash and all required integrity guarantees.
If I have a RRSIF-compliant SIF, am I already compliant with B2B e-invoicing?
No. The RRSIF governs the integrity of the system that generates invoices. B2B e-invoicing governs the format in which those invoices are exchanged between businesses. They are independent layers of obligation.
Which of the three changes affects me first?
The SIF: freelancers have until 1 July 2027 and companies until 1 January 2027. B2B e-invoicing has no start date yet as it depends on the pending Ministerial Order. In practice, SIF and VeriFactu requirements arrive first for most businesses.
What is "dual-use software" that the RRSIF aims to eliminate?
Software programmes that allow businesses to conceal sales, delete invoices or manipulate accounting records without leaving a trace. By requiring invoicing records to be immutable and chained with a hash, the RRSIF makes any subsequent modification detectable.
Are the penalties for non-compliance with the RRSIF significant?
Yes. Using software that does not comply with the RRSIF requirements can result in penalties of up to €50,000 per tax year for the user, and up to €150,000 per tax year for the producer or distributor.
Conclusion: three changes, three timelines, one structured adaptation strategy
The regulatory map of Spanish invoicing in 2026-2027 is complex but manageable once the structure is understood. There are three real changes: adapting software to the RRSIF (SIF), deciding whether to operate in VeriFactu or Non-VeriFactu mode, and preparing to issue and receive invoices in structured format when B2B e-invoicing comes into force.
The key for businesses and advisors is not to treat these three changes as one. Each has its own regulation, its own timeline and its own specific technical requirements. Addressing them separately and in a planned manner is the most efficient way to reach 2027 with all systems in order.