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Ley Crea y Crece, SII, and VERIFACTU: Spain's Invoicing and Reporting Mandates

A practical guide to Spain's three invoicing mandates, Crea y Crece, SII, and VERIFACTU, covering who each applies to and how Facturae fits in.

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Crea y Crece, SII, and Verifactu get mentioned in the same breath so often that it's easy to assume they're three competing ways to handle the same requirement.

They aren't.

Each one is a separate mandate governing a different question: who must issue structured B2B invoices, who must report VAT data in real time, and whose invoicing software must be certified, and a single business can be subject to more than one at once. Facturae sits underneath all three as the older B2G invoice format, not a fourth mandate competing for the same slot.

This guide untangles which mandate applies to which business. fiskaly's Fiscal Compliance in Spain 2026 guide already covers the practical 2026-to-2027 readiness timeline for software vendors. So, in this piece we focus on what each mandate actually requires and how they relate.

TL;DR

  • Ley Crea y Crece (Law 18/2022) is Spain's B2B e-invoicing mandate. Its technical regulation, Real Decreto 238/2026, was published in March 2026; the Ministerial Order that starts the compliance countdown is expected around October 2026, ahead of an October 2027 deadline for businesses over €8 million in turnover and October 2028 for everyone else, regardless of size.
  • SII (Suministro Inmediato de Información) is a real-time VAT reporting obligation, in force since July 2017 for businesses with turnover above €6 million, VAT groups, and businesses under the monthly refund scheme, requiring invoice data to reach the tax agency within four working days.
  • Verifactu is an anti-fraud software certification regime that applies to businesses below SII's €6 million turnover threshold; it becomes mandatory for corporate taxpayers from January 1, 2027, and for all other taxpayers from July 1, 2027.
  • SII and Verifactu are mutually exclusive, but only in one direction: a taxpayer under €6 million in turnover can opt into SII instead of Verifactu, while a taxpayer already required to use SII cannot choose Verifactu instead.
  • Ley Crea y Crece layers on top of SII and Verifactu rather than replacing either, and will apply to every business invoicing another business domestically, regardless of size, once its Ministerial Order takes effect. Facturae, as a document format rather than a mandate, sits outside this comparison.
  • Regional systems add further complexity: TicketBAI is already in force across the Basque Country, and NaTicket, its Navarra equivalent, is not yet in force. Both sit entirely outside Verifactu, which doesn't apply in either region, but not outside SII, which is a national obligation that still applies there.

Where does Facturae fit in?

Facturae is Spain's structured XML invoice format, mandatory for B2G invoicing to public administrations since January 2015 under Ley 25/2013, submitted through the FACe platform with a digital signature attached.

It defines the document itself, what data the invoice carries and in what structure, not how or whether that data gets reported to the tax agency separately. A supplier invoicing a Spanish public body needs a Facturae-format XML file signed and transmitted through FACe. Facturae also appears as one of the accepted syntaxes under Real Decreto 238/2026, alongside UBL aligned with EN 16931, so it doesn't disappear once Ley Crea y Crece takes effect. It simply isn't a mandate in the way SII, Verifactu, and Crea y Crece are, which is why it sits outside the three-way comparison in this guide.

What is SII, and how?

SII (Suministro Inmediato de Información) is a real-time VAT reporting obligation, entirely separate from Facturae, requiring in-scope businesses to send invoice data to the tax agency within four working days of issuing or receiving an invoice.

It's been mandatory since July 1, 2017 for companies with annual turnover above €6 million, businesses under the monthly VAT refund scheme (REDEME), and VAT groups, covering an estimated 75,000 taxpayers. Businesses under that €6 million threshold can also opt into SII voluntarily instead of Verifactu, though the choice only runs one way: a business obligated to use SII cannot switch to Verifactu instead. SII doesn't require a specific invoice format the way Facturae does; a business can still issue ordinary PDF or paper invoices while separately reporting the underlying data to the AEAT. It also applies nationally, including in the Basque Country and Navarra, where TicketBAI and NaTicket separately govern certified invoicing software but don't replace SII's reporting duty. That's the core distinction: Facturae governs the invoice document itself, while SII governs a parallel data-reporting duty that applies regardless of which format the invoice was issued in.

What is Verifactu, and who actually needs it?

Verifactu is an anti-fraud software certification regime, part of the broader SIF (Sistemas Informáticos de Facturación) framework, that applies to businesses below SII's €6 million turnover threshold rather than governing a specific invoice format or reporting deadline.

Software vendors have had to deliver Verifactu-compliant systems since July 2025, but the obligation for businesses themselves to actually use certified software follows later: January 1, 2027 for Corporate Income Tax (Impuesto sobre Sociedades) taxpayers, and July 1, 2027 for everyone else. Critically, SII and Verifactu are mutually exclusive, but only in one direction: a business under the €6 million threshold can opt into SII instead, in which case Royal Decree 254/2025 exempts it from Verifactu entirely, but a business already required to use SII has no equivalent option to fall back to Verifactu. SII's real-time reporting already achieves the same anti-fraud visibility Verifactu is designed to provide, which is the logic behind the exemption running only one way. Verifactu also doesn't apply in the Basque Country or Navarra, where TicketBAI and NaTicket cover the equivalent certified-software requirement instead.

What is Ley Crea y Crece, and does it replace any of these?

No. Ley Crea y Crece (Law 18/2022) layers on top of SII and Verifactu rather than replacing either, and it will apply to every business invoicing another business domestically, regardless of size, once its Ministerial Order takes effect.

The law itself dates back to September 2022, but its technical detail waited on a further regulation for over three years. Real Decreto 238/2026, published in the BOE on March 31, 2026, finally set the accepted formats, UBL aligned with EN 16931, alongside Facturae, and the interconnection requirements between platforms. That Real Decreto still deferred the actual start of the compliance countdown to a separate Ministerial Order, expected around October 2026 at the time of writing. Once that Order takes effect, businesses with turnover above €8 million get 12 months to comply, landing around October 2027, and every other business or self-employed professional, regardless of size, gets 24 months, landing around October 2028. Unlike SII and Verifactu, which split obligations by turnover, Crea y Crece doesn't carve out an exemption by size; only the deadline changes. A single mid-sized company could realistically be subject to SII for its reporting obligations, Facturae and FACe for its public-sector invoices, and eventually Crea y Crece for its private-sector sales, three mandates running concurrently rather than one replacing another.

Spain's invoicing systems at a glance

SystemWhat it governsWho it applies toStatus
Ley Crea y Crece (B2B)Structured domestic B2B invoicingEvery business invoicing another business, regardless of sizeRD 238/2026 published; Ministerial Order (and countdown) expected Oct 2026
SIIReal-time VAT data reportingTurnover >€6M, REDEME, VAT groups — national, incl. Basque Country/NavarraMandatory since July 2017
VerifactuCertified invoicing softwareTaxpayers below the SII threshold, outside Basque Country/NavarraMandatory Jan/Jul 2027
Facturae / FACeB2G invoice format and signatureSuppliers to public administrationsMandatory since 2015; also an accepted Crea y Crece syntax
TicketBAI / NaTicketRegional certified invoicingBasque Country / Navarra businessesTicketBAI in force; NaTicket not yet in force; separate from Verifactu, not from SII

Key takeaways

These are three different mandates, not three competing options. Crea y Crece governs B2B invoicing, SII governs real-time reporting, and Verifactu governs certified software. Facturae remains a separate, older format question underneath all three, not a fourth option.

SII and Verifactu don't stack, and the exemption only runs one way. A business under €6 million can choose SII over Verifactu; a business already on SII has no equivalent option to fall back to Verifactu.

Crea y Crece doesn't split by size, only by deadline. Every business invoicing another business domestically will eventually be in scope, regardless of turnover; the €8 million threshold only decides whether the deadline lands around October 2027 or October 2028.

The Ministerial Order, not the Real Decreto, is what starts the clock. Real Decreto 238/2026 set the technical detail in March 2026; the actual compliance countdown only begins once the still-pending Ministerial Order, expected around October 2026, takes effect.

Regional systems overlap with SII, not with Verifactu. TicketBAI and NaTicket sit outside Verifactu entirely, but SII is a national obligation that still applies in the Basque Country and Navarra alongside them.

Untangling which mandate applies to which business is only the first step. fiskaly's guides on SII vs. Verifactu: The AEAT's Technical Differences and Verifactu, Crea y Crece: Law Enforcement Updates go deeper on the reporting-versus-certification distinction and the enforcement picture behind Crea y Crece specifically. fiskaly's guides on Spain E-Invoicing & VERIFACTU: The Two-Phase Rollout, E-Invoicing vs. E-Reporting: What's the Difference?, and What Is EN 16931? The European E-Invoicing Standard Explained go deeper on Spain's phased rollout timeline, the general distinction between invoicing and reporting obligations, and the European standard behind Crea y Crece's own format choice (all part of the same content series; not yet published at the time of writing). For the practical 2026-to-2027 readiness picture for software vendors, fiskaly's Fiscal Compliance in Spain 2026 guide and Verifactu integration FAQ cover the deadlines and technical requirements directly.

Frequently asked questions

No. Crea y Crece is Spain's upcoming B2B e-invoicing mandate, SII is a real-time VAT data-reporting obligation, and Verifactu is a certified-software regime. Facturae, a separate B2G invoice format, sits underneath all three rather than competing with them. A business can be subject to more than one mandate at once.

No. SII only requires reporting invoice data to the AEAT within four working days; the underlying invoice can still be a PDF or paper document.

Only in one direction. A taxpayer under €6 million in annual turnover can opt into SII instead of Verifactu. A taxpayer already required to use SII, because its turnover exceeds €6 million or for another qualifying reason, has no equivalent option to use Verifactu instead.

January 1, 2027 for Corporate Income Tax taxpayers, and July 1, 2027 for all other taxpayers below the SII threshold. Software vendors have had to deliver compliant systems since July 2025.

Not yet. Its technical regulation, Real Decreto 238/2026, was published in March 2026, but the compliance countdown only starts once a separate Ministerial Order takes effect, expected around October 2026. From that date, businesses over €8 million in turnover get 12 months to comply, and every other business or self-employed professional, regardless of size, gets 24 months.

Not on its own. Facturae applies to B2G invoicing. Domestic B2B invoicing will be governed by Ley Crea y Crece once its Ministerial Order takes effect, though Facturae itself remains one of the accepted formats under that regulation.

Partly. Both sit entirely outside Verifactu, which doesn't apply in the Basque Country or Navarra, but not outside SII, which is a national obligation that still applies in both regions. TicketBAI is already in force across the Basque Country; NaTicket, its Navarra equivalent, is not yet in force.

fiskaly SIGN ES covers Verifactu, TicketBAI, SII, and NaTicket through a single API, alongside fiskaly's e-invoicing solution for Facturae and the upcoming Crea y Crece mandate.

Next steps

Which mandate actually applies to a given business depends on turnover, transaction type, and region, not a single national rule. fiskaly SIGN ES covers Verifactu, SII, TicketBAI, and NaTicket compliance through one API, alongside fiskaly's e-invoicing solution for Facturae and the upcoming Crea y Crece mandate.

Related reading: Spain E-Invoicing & VERIFACTU: The Two-Phase Rollout, E-Invoicing vs. E-Reporting: What's the Difference?, and What Is EN 16931? The European E-Invoicing Standard Explained (all part of this same content pillar; not yet published at the time of writing).

Last updated: August 2026. This article is general guidance, not legal advice. The Ley Crea y Crece Ministerial Order was still pending at the time of writing; confirm its publication date and the resulting deadlines, along with current SII, Verifactu, and Facturae rules, against the Agencia Tributaria's (AEAT) official guidance.