Verifactu vs Crea y Crece: The Two Spanish Laws Everyone Confuses
Spain has two e-invoicing laws with two different deadlines, and the market systematically confuses them. Verifactu is about your software. Crea y Crece is about the document and its exchange. Here is the difference.
Verifactu vs Crea y Crece: The Two Spanish Laws Everyone Confuses
Spain has two separate e-invoicing regulations, months apart, with staggered deadlines. The market talks about them as if they were one. They are not. One governs the software you use. The other governs the document you exchange. Confusing them is expensive: prepare for both in one project and the work is done once. Rush one and tackle the other later, and you pay twice.
Side by Side
| Verifactu | Crea y Crece | |
|---|---|---|
| Legal basis | RD 1007/2023 (Ley Antifraude, Law 11/2021) | Law 18/2022, art. 12 + RD 238/2026 |
| What it regulates | Billing software (SIF) | Invoice format and B2B exchange |
| Relationship | Issuer to tax authority (AEAT) | Issuer to recipient, with AEAT visibility |
| Core mechanism | Immutable, hash-chained invoice records; QR code on every invoice | Structured, signed invoice (Facturae/UBL/CII) exchanged via platforms |
| Deadline | 1 Jan 2027 (companies), 1 Jul 2027 (self-employed) | Oct 2027 (turnover above 8M EUR), Oct 2028 (all others) |
| Exemptions | SII-enrolled taxpayers; TicketBAI regions | None by turnover once in force |
Verifactu: The Software Law
Verifactu (from "verificación de facturas") is an anti-fraud framework. It does not change what an invoice looks like between you and your customer. It changes what your billing software must do internally.
Under RD 1007/2023, any Sistema Informático de Facturación (SIF) must:
- Generate an immutable registration record for every invoice
- Chain records with a cryptographic hash, so any alteration of a past record breaks the chain
- Guarantee integrity, traceability, accessibility, and readability of all records
- Print a QR code on every invoice, linking to the AEAT verification service
Optionally, the SIF can transmit each record to AEAT in near real time ("Verifactu mode"). Transmission is not mandatory; immutability and the QR are.
Verifactu applies to almost all companies and self-employed professionals in the common territory of Spain, except those enrolled in SII (who already report near-real-time) and businesses under TicketBAI in the Basque Country.
Crea y Crece: The Document and Exchange Law
The Crea y Crece Law (Law 18/2022, article 12) obliges businesses and professionals to issue electronic invoices in every B2B transaction. The implementing decree, RD 238/2026, entered into force on 20 April 2026 and defines how.
Key mechanics:
- Structured and signed format. Facturae (the Spanish standard) or interoperable formats (UBL, CII). A PDF sent by email does not satisfy the obligation once your deadline arrives.
- Exchange channels. Accredited private e-invoicing platforms, which must interconnect, plus a free public AEAT platform. A UBL copy reaches the AEAT public solution regardless of channel.
- Status reporting. Both parties must report invoice status (acceptance, rejection, payment) within 4 calendar days.
- Policy goal. Late payment. Spain averages around 80-day payment delays against a 60-day legal maximum. Traceable invoice status gives the state visibility into payment terms.
Why the Confusion Costs Money
The two laws share vocabulary (electronic invoice, QR, platforms, AEAT) but demand different work:
- Verifactu demands software certification: your SIF must be compliant, whether it is a commercial product, an ERP module, or an in-house system.
- Crea y Crece demands exchange integration: connection to an accredited platform or the AEAT public solution, structured format generation, and a status-reporting workflow.
A business that "does Verifactu" in 2026 and stops there will discover in 2027 that it still cannot exchange structured B2B invoices. A business that builds only the exchange layer will run it on non-certified software. Both pay for the second project under deadline pressure, when implementers are saturated.
The Regional Layer
Two autonomous regions complicate the map further:
- Basque Country (Alava, Bizkaia, Gipuzkoa): TicketBAI replaces Verifactu entirely. Bizkaia adds Batuz and the LROE ledger.
- Navarra: NaTicket, modeled on TicketBAI, rolling out with sector-by-sector timelines.
Crea y Crece applies regardless of region. A Bilbao company is exempt from Verifactu via TicketBAI, but not from B2B e-invoicing.
What To Do Now
- Classify your obligations separately. Verifactu status (are you in SII? in the Basque Country?) and Crea y Crece status (what is your turnover? which deadline?).
- Audit your software. Is your SIF already certified or on the vendor's certification roadmap? In-house and legacy systems need migration plans now.
- Plan one project with two workstreams. Software compliance and exchange integration, sequenced to your two deadlines.
- Do not wait for Q2 2027. Implementers will be saturated. The postponement to 2027 is a window, not a reprieve.
This material is information of a general nature and does not constitute legal or tax advice. For a specific situation, verify the current rules or consult a qualified adviser.