Crea y Crece (Ley 18/2022, “Law on the Creation and Growth of Companies”) is a Spanish law introducing mandatory B2B electronic invoicing for all businesses and professionals established in Spain.Its primary policy goal is combating late payments. Spain has one of the longest average payment periods in the EU (~80 days), and the law forces structured, traceable data on every B2B invoice, plus mandatory invoice status reporting (acceptance, rejection, payment date) so payment behavior becomes visible and measurable.Key parameters as they stand now:
Scope: domestic B2B transactions where the recipient is a business or professional established in Spain.
Architecture: hybrid — a free public AEAT platform plus interoperable private platforms.
Format: EN 16931-compliant UBL is mandatory for the public solution and for copias fieles submitted from private platforms; Facturae, UBL, CII and EDIFACT are accepted between private platforms.
Timeline: Royal Decree 238/2026 was published 31 March 2026; the Ministerial Order is expected to enter force 1 October 2026, triggering the clocks — 12 months later for companies with turnover >€8M, 24 months later for everyone else, with status reporting deferred a further year for sole traders / IRPF attribution entities.
This regulation aims to transform invoicing from “PDF by email” into a structured, reportable, interoperable network.
Who can issue invoices in Spain?
Any entity with a Spanish NIF — companies, autónomos, and foreign entities with Spanish fiscal presence. Foreign-only entities issuing into Spain must operate through their local fiscal representation or a non-resident NIF.
What periodic reporting obligations exist in Spain?
Quarterly or monthly VAT (Modelo 303), annual recap (Modelo 390), recapitulative intra-EU declaration (Modelo 349), and the annual third-party transactions return (Modelo 347). Crea y Crece (2027) adds invoice status reporting (acceptance, rejection, payment date) on top.
Facturae
When is Facturae mandatory in Spain?
Mandatory for B2G transactions with Spanish public administrations above €5,000 since 2015 (Ley 25/2013). Voluntary for B2B today; will become broadly mandatory once Crea y Crece’s implementing decree takes effect (currently expected 2027).
Are there special supplier obligations under Facturae?
For B2G submissions, the supplier needs a valid digital certificate recognized by FACe (Cl@ve, FNMT, etc.). For Invopop-generated XAdES signatures the certificate is Invopop’s own; suppliers using their own signing flow upload theirs.
What are the legal obligations for receiving Facturae invoices?
Spanish public administrations must accept Facturae through FACe or a regional equivalent (e-FACT in Cataluña, FACeB2B for B2B). Private sector recipients have no Facturae-specific obligations beyond the standard 4-year archival.
No-VERI*FACTU
What is the No-VERI*FACTU mode?
“No-VERI*FACTU” is the alternative compliance mode under the same Spanish billing-software regulation (Reglamento de Sistemas Informáticos de Facturación). Invoices are not sent to AEAT in real time; instead they are registered locally in the certified system and may be inspected on demand. Suitable for businesses that prefer to keep records private unless asked.
Are there special supplier obligations under No-VERI*FACTU?
Same fiscal residence requirements as VERI*FACTU. Additionally, the supplier must be able to produce the chained register on AEAT request; Invopop retains it on their behalf for the legally required period.
SII
Who is required to report through SII?
SII (Suministro Inmediato de Información) is mandatory for taxpayers that file VAT on a monthly basis. In practice this includes companies with annual turnover above €6,010,121.04, members of VAT groups (REGE), and businesses registered in the monthly VAT refund register (REDEME). Other taxpayers can opt in voluntarily.
Are there special supplier requirements under SII?
The supplier must be a Spanish-resident taxpayer subject to SII (turnover > €6M, REGE, or REDEME) or have voluntarily opted in. They must hold a digital certificate for AEAT or appoint Invopop as their representative via signed agreement.
What reporting obligations does SII impose?
Issued and received invoices must be reported within 4 calendar days. Subsequent corrections, cancellations, and intra-EU operations have additional bookkeeping streams (Libro de Bienes de Inversión, Libro de Operaciones Intracomunitarias).
TicketBAI
Do I need a digital certificate or any registration with TicketBAI?
No, you don’t need to register with TicketBAI, or upload any digital certificates to Invopop. As a certified billing provider, Invopop will sign all invoices with our own digital certificate.TicketBAI allows three types of certificates; Invopop uses the certificado sello de empresa which allows us to sign e-invoices on behalf of our customers, saving you the burden of registering and uploading certificates yourself.
What is the deadline for uploading TicketBAI invoices from the time the sale is made?
Bizkaia: by the end of each quarter, except for companies under SII (turnover above 6 million euros), which must report within 4 days.
Gipuzkoa and Álava: The submission must be done immediately after generating the invoice.
What is needed to issue TicketBAI?
The supplier must have fiscal residence in one of the three foral territories (Bizkaia, Gipuzkoa, Álava) and sign a representation agreement allowing Invopop to issue on their behalf. No supplier-side certificate required.
VERI*FACTU
Has VERI*FACTU been delayed until 2027?
Following congress approval, the VERI*FACTU mandate has been postponed by one year. The new dates are:
January 1, 2027 for companies
July 1, 2027 for self-employed individuals.
Is VERI*FACTU compliance mandatory in Spain?
VERI*FACTU will be mandatory for companies from January 1st, 2027. The rest of taxpayers (mainly self-employed individuals) from 1 July 2027. Companies reporting with SII (large companies) or TicketBAI are exempt from reporting with VERI*FACTU.
Do VERI*FACTU invoices need to be printed?
VERI*FACTU invoices don’t necessarily need to be printed because they are issued with electronic invoicing systems such as Invopop. Source: AEAT FAQ.
Can invoices have an issue date in the past in VERI*FACTU?
Yes, VERI*FACTU allows issue dates to be in the past, as long as they are after October 28, 2024. The issue date can’t be set with a date in the future. The AEAT is not strict about the validation, but it’s best to keep your intentions clear. GOBL gives you alternative fields such as op_date and value_date to store details about your invoicing operation.
What if a customer exceeds the simplified invoice limit (400€) and is not registered in the taxpayer census?
Spanish fiscal law requires the customer to be identified with an ID document (preferably official). Set the es-verifactu-identity-type extension to 07 (“Not registered in census” / “No censado”), which maps to the IDOtro field in VERI*FACTU.Here is an example of a customer identity block in GOBL:
For the full list of identity type codes, see the es-verifactu-v1 addon documentation.
Are there special supplier obligations under VERI*FACTU?
Suppliers must use a certified billing system (Invopop is one). Each supplier must sign a representation agreement allowing Invopop to issue invoices on their behalf — without a digital certificate from the supplier’s side.
Should I send credit notes with positive or negative values?
You should send the credit note with the same sign as the original invoice.In Spain, unlike other countries, credit notes must be submitted to Hacienda with inverse values. Invopop handles this conversion automatically before transforming the credit note into a “factura rectificativa” (corrective invoice).This means you only need to send the credit note following international standards (with same sign as the invoice). Invopop will automatically adapt it when submitting to Hacienda.For reference, see the GOBL Invoice documentation with type set to credit-note.
Where do I find Spain-specific GOBL documentation?
Invopop is working on direct FACe connection as part of the 2027 Crea y Crece mandate
You submit the XML directly to the FACe portal, Invopop does not submit it for you. FACe is the centralised entry point for all Spanish public administrations, and submission is the supplier’s responsibility. You’ll need:
A valid digital certificate (FNMT or DNIe).
The XML file Invopop generated (download it from the workflow output).
The three DIR3 administrative centres correctly embedded in the invoice — Oficina Contable (01), Órgano Gestor (02), Unidad Tramitadora (03). If these are wrong, FACe will reject the invoice. The receiving public body publishes their codes in the DIR3 directory.
Submission options:
FACe web portal: manual upload, fine for low volumes.
A registered FACe-compatible third party (gestoría, ERP plugin, etc.).
How do I verify that the generated XML is valid?
The generated XML will be added to your silo entry as an attachment under the “files” tab with the file name facturae.xml. Upload this file to FACe’s online validator to verify its validity.
Is the Facturae invoice reported to the tax authority?
No — the Facturae app only converts GOBL to Facturae XML. Submit B2G invoices via FACe; tax reporting to the AEAT happens separately (e.g. through SII or VERI*FACTU).
No-VERI*FACTU
What GOBL fields differ between VERIFACTU and No-VERIFACTU?
The same GOBL invoice produces either, controlled by the workflow. The QR payload and the absence of verifactu-qr stamps in the silo entry distinguish No-VERI*FACTU output. AEAT submission stamps are absent in No-VERI*FACTU mode.
SII
What is the deadline for submitting invoices to SII?
Issued invoices must be reported within 4 calendar days from the date of issuance — and always before the 16th day of the month following the one in which the VAT liability arises. Saturdays, Sundays, and national holidays are excluded from the count. Received invoices follow the same 4-day rule but starting from the date the invoice is recorded in the books.
How do I correct an invoice already submitted to SII?
SII corrections are submitted as modification records (A1) referencing the original entry, rather than by deleting and re-sending. In practice, after fixing the underlying GOBL document, run the SII workflow again — Invopop detects that a previous submission exists for the same invoice and emits the modification record automatically.
TicketBAI
What's the workflow for issuing TicketBAI invoices?
Build a GOBL invoice with the es-tbai-v1 addon, send it through the TicketBAI Issue Invoice workflow. Invopop signs with its sello de empresa certificate, generates the chained XML, and submits to the relevant Diputación Foral (Bizkaia, Gipuzkoa, or Álava).
Why don't TicketBAI QR codes work in the sandbox environment?
This is expected. QR codes generated in the TicketBAI sandbox environment are intentionally non-functional to prevent sandbox invoices from being mistaken for real ones.To verify that a sandbox QR code is correct, upload the PDF or a QR image to the foral tax authority’s test verification page: pruebatuz.bizkaia.eus.
VERI*FACTU
When should I cancel invoices in VERI*FACTU?
In VERI*FACTU, you should only cancel an invoice if it hasn’t been handed to the customer nor accepted by the tax authority. Different from a credit note or a corrective, canceling an invoice doesn’t produce a second document, which means you don’t have a paper to hand to your customer to show the cancellation. That’s why, if the invoice has been handed to the customer, we recommend issuing a credit note instead.
What should I do if an invoice is rejected by VERI*FACTU?
The response from VERI*FACTU should contain all the details you need to be able to decide what changes need to be made to the GOBL document in order to be processed correctly. Make the changes either via the Invopop API or console directly on the same document, and simply resend to the VERI*FACTU workflow.Invopop will ensure that the correct substitution document is generated by checking previous attempts and including the correct codes in the new request.
Once a VERI*FACTU invoice is issued, can I get the QR code image url?
We do not provide the QR code image itself. The QR code is a visual representation of a URL that you need to generate on your own if you’re creating custom PDFs or need it for any other purpose.The full requirements are in the AEAT VERI*FACTU QR specification PDF document in Spanish. Here you can read that:
The “QR” code must have a size between 30x30 and 40x40 millimeters and follow the specifications of the ISO/IEC 18004:2015 standard. For the generation of the “QR” code, the M (medium) error correction level shall be used.
Generate your own QR code image as follows:
1
Obtain the VERI*FACTU URL
API: fetch the entry and get data -> head -> stamps -> verifactu-qr.
Console: in the invoice entry click on the kebab ··· menu and select View Headers.
2
Generate the QR image
Use the VERI*FACTU URL in a library capable of generating ISO/IEC 18004:2015 QR images (Invopop uses go-qr)
VERI*FACTU requires every request to be linked with a fingerprint or hash. During the “Generate VERI*FACTU” and “Cancel VERI*FACTU” actions, Invopop will automatically find the last request made for the same supplier, and incorporate the chained data into the new request.It’s important to understand that VERI*FACTU focuses on requests, and not individual documents; a single invoice may have multiple entries in the chain if it has been processed multiple times due to incorrect details, cancellations, or substitutions.Invopop guarantees the chain is never broken using database transactions and retries in the case of collisions.
What are the most common errors when submitting invoices to VERI*FACTU?
The most common errors are related to format issues or invalid extensions, which are already handled in Invopop through the es-verifactu-v1 addon validations. These prevent most of the typical problems before they reach the submission stage.Among the errors that aren’t yet validated on our side, the five most frequent ones are:
4104: Error en la cabecera: el valor del campo NIF del bloque ObligadoEmision no está identificado. → The issuer’s name must match what’s registered for that NIF (tax ID).
4102: El XML no cumple el esquema. Falta informar campo obligatorio. → Usually occurs when a required field is missing in the XML, often within the Desglose (taxes) section.
1110: El NIF no está identificado en el censo de la AEAT. → The provided NIF (tax ID) isn’t found in the AEAT registry (often due to typos or testing data).
3000: Registro de facturación duplicado. → Triggered when issuing the same invoice series/code twice.
2001: El NIF del bloque Destinatarios no está identificado en el censo de la AEAT. → Similar to 1110, but applies to the NIF (tax ID) of the customer.
In my VERI*FACTU's XML, DescripcionOperacion is being populated with line item descriptions, how do I change this?
You can set your own description using the notes object in the invoice. The key used for the description needs to be set to general. For example:
"notes": [ { "key": "general", "text": "This will appear as DescripcionOperacion" } ]
We generate a default description if the note is not provided which is what you are currently seeing. This default description will neatly cut off before it reaches a length of 500 characters as that is the limit the AEAT imposes.
What $tags are supported in GOBL with the 'es-verifactu-v1' addon?
Key
Text
reverse-charge
Reverse Charge / Inversión del sujeto pasivo.
simplified-scheme
Factura expedida por contribuyente en régimen simplificado.
self-billed
Facturación por el destinatario.
travel-agency
Régimen especial de las agencias de viajes.
second-hand-goods
Régimen especial de los bienes usados.
art
Régimen especial de los objetos de arte.
antiques
Régimen especial de las antigüedades y objetos de colección.
cash-basis
Régimen especial del criterio de caja.
How do I invoice a line with no VAT in Spain (exempt, not subject, reverse charge or 0%)?
In Spanish VAT there are several legally distinct reasons why a line carries no tax, and VERI*FACTU requires you to state which one applies. In GOBL you do this with the key field of the line’s tax combo. The es-verifactu-v1 addon derives everything else from it.Pick the key that matches the reason there is no VAT:
Situation
key
Default extension set by the addon
When to use it
Exempt under art. 20 LIVA
exempt
es-verifactu-exempt: E1
Healthcare, education, financial and insurance services, residential rental, second-hand property, games of chance subject to the gaming tax, and the other domestic exemptions in art. 20.
Exempt for another legal reason
exempt + es-verifactu-exempt: E6
—
Exemptions whose legal basis is outside arts. 20–25. Rare.
Export of goods
export
es-verifactu-exempt: E2, es-verifactu-regime: 02
Goods leaving the EU, including shipments to the Canary Islands, Ceuta and Melilla. Set E3 for supplies assimilated to exports (ships, aircraft, diplomatic missions) or E4 for goods in free zones and customs warehouses.
Intra-community supply of goods
intra-community
es-verifactu-exempt: E5
Goods transported to another EU member state for a customer with a valid VAT number in that state.
Not subject – place of supply
outside-scope
es-verifactu-op-class: N2
Services to business customers established outside Spain, services localised in the Canary Islands, Ceuta or Melilla, goods that never enter Spain.
Not subject – art. 7, 14 and others
outside-scope + es-verifactu-op-class: N1
—
Transfer of a going concern, free samples and low-value promotional items, compensation and penalties, refundable deposits, pass-through amounts collected for third parties.
Domestic reverse charge
reverse-charge
es-verifactu-op-class: S2
Construction and rehabilitation works between businesses, scrap and waste metals, property transfers where the exemption is waived, B2B sales of phones, consoles and laptops to resellers. The invoice must state Inversión del sujeto pasivo.
Do not include rate or percent on any of these lines. None of these keys admits a rate, so a combo such as key: exempt with rate: general fails validation (GOBL-TAX-COMBO-03) before the invoice is sent. The addon also rejects a combo that carries both an operation class and an exemption code, and requires an operation class on any combo with a percent.ExamplesAn exempt healthcare service:
{ "cat": "VAT", "key": "exempt"}
An exempt operation with a legal basis outside art. 20:
Construction work for a Spanish business, with the customer self-assessing:
{ "cat": "VAT", "key": "reverse-charge"}
The customer’s tax ID does not change the classification: a line with rate: standard is taxed at 21% and marked S1 even when the customer is German. The only automatic case is a tax combo whose country field is not ES, meaning you are charging another country’s VAT on the line. The addon then marks it N2 for VERI*FACTU and drops any exemption code, because the operation is not subject to Spanish VAT.Is there a 0% rate?Not one you can use today. GOBL accepts key: zero, which classifies the line as subject and not exempt (S1) at 0%, but Spain has no 0% VAT rate in force: the temporary 0% on basic foodstuffs ended on 30 September 2024, and the AEAT validates the rate against the operation date and rejects 0% on later invoices. If your system has a product configured at 0%, it is almost certainly modelling one of the cases in the table above and should be mapped to that key instead.Prepaid credit, gift cards and advancesThese are not exempt and should not use any of the keys above. Credit that can only be spent on one kind of supply at a known rate is taxed when sold, as a normal rate: standard line. Credit that can be spent on goods or services at different rates is outside the scope of VAT when sold and is taxed on redemption instead; no invoice for a supply is issued at the time of the top-up. Advance payments for a specific future supply are taxed when received, at the rate of that supply.Who decides which key applies?The classification is a tax determination for the issuer and their advisor. GOBL validates that what you send is internally consistent and will be accepted by the AEAT, but it cannot tell you whether a given product is exempt, not subject or taxed. The same reason must also appear on the printed invoice: an exempt line needs a reference to its legal basis, and a reverse-charge line needs the Inversión del sujeto pasivo mention.
What are the most common reasons for failing supplier approval?
We reject agreements when:
The uploaded document is not signed (they upload the unsigned template).
Users upload a handwritten signature without an ID.
The electronic signature is made with an FNMT certificate.
The agreement is missing a date or location.
The name is entered as an email address.
The job will state the reason for rejection.
What happens if a supplier does not complete their registration within the allotted wait time?
A KO will be triggered and the supplier will be labelled with the Error state. We currently recommend sending a reminder to the supplier through a webhook.The registration link will not expire and the entity will still be able to upload their registration documents which will be validated. Should you choose to run this workflow again using this supplier, the supplier will be accepted or rejected immediately because the required documentation has already been provided and validated.
What happens if a supplier validation is rejected?
If the uploaded agreement documents were rejected, a KO will be triggered and the supplier will be labelled with the Error state. We currently recommend sending a notification to the supplier through a webhook within the Error Handling section.Afterwards, if you wish to re-register the supplier with new documents, you must:
Unregister the supplier using the Unregister Supplier workflow.
Re-run the Register supplier workflow.
This will restart the entire registration process. When uploading documents, the previously submitted agreement will appear selected by default. Simply choose a new file and click Continue to override the old one. See the image below for reference:
Overriding the previously submitted agreement
What is the minimum information required to register a supplier?
In order to complete the representation agreement you will need to provide the following information:Company
What methods are available to sign the PDF supplier agreements?
The supplier can add their electronic signature to the PDF document (instructions), or sign with a handwritten signature (we recommend using Adobe’s online service).
What is the file size limit for the documents provided in the supplier registration flow?
Individual documents are limited to a maximum size of 10MB. Uploads exceeding this size will result in an error.
Facturae
How do I register a supplier with Facturae?
Facturae itself has no central registration — the supplier just needs to enrol on FACe (or the relevant regional portal) using their digital certificate. Invopop signs the XML; submission to FACe is currently manual via the supplier’s account.
What certificates does Facturae require to authenticate a supplier?
Facturae requires an XAdES signature on the XML using a qualified certificate (FNMT persona jurídica, Cl@ve, ACCV, etc.). Invopop signs with its own certificate by default; bring-your-own is supported on request.
No-VERI*FACTU
How do I register a supplier with No-VERI*FACTU?
Run the No-VERI*FACTU Register Supplier workflow. The agreement is identical to VERI*FACTU’s, but Invopop does not register the supplier with AEAT for active reporting, only for invoicing on their behalf.
SII
How do I register a supplier with SII?
Run the SII Register Supplier workflow. The supplier signs the representation agreement and Invopop registers as their colaborador social with AEAT. Invopop’s own certificate is then used for SII submissions on their behalf.
What certificates does SII require to authenticate a supplier?
SII web services accept any AEAT-recognized certificate. Invopop signs submissions with its certificado de representante de persona jurídica, acting under the colaborador social arrangement — suppliers do not upload their own certificates.
TicketBAI
How do I register a supplier with TicketBAI?
Run the TicketBAI Register Supplier workflow. The legal representative signs the agreement (electronic or handwritten + ID); the supplier’s foral territory determines which Diputación Foral endpoint Invopop will submit to.
What certificates does TicketBAI require to authenticate a supplier?
None — Invopop uses its own certificado sello de empresa (one of the three TicketBAI-permitted types). Suppliers do not need to register with the foral tax authority or upload any certificate.
VERI*FACTU
How do I register a supplier with VERI*FACTU?
Run the VERI*FACTU Register Supplier workflow. The legal representative signs the PDF agreement (electronic or handwritten signature with ID) and Invopop registers the supplier with AEAT for invoicing on their behalf.
Continuously, every issued or received invoice must be reported within 4 calendar days (excluding weekends and holidays), and always before the 16th of the following month. There is no daily cadence; submissions happen as documents are processed.
What format does SII expect for periodic reports?
SOAP web services with XML payloads — distinct schemas for issued (SuministroFactEmitidas), received (SuministroFactRecibidas), investment goods, and intra-EU operations. Each call carries up to 10,000 records signed with the issuer’s (or representative’s) certificate.
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