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VeriFactu or SII: which one applies to you, how they differ and what happens if you cross the threshold

This guide covers Spanish regulations.

You don't get to choose: the law chooses for you, based on how you file your VAT. What is your decision is having software that doesn't get stuck in one of the two on the day your turnover moves into a different band.

The rule in one line: they are mutually exclusive. If you are in the SII, VeriFactu does not apply to you. So says Article 3.3 of the Regulation approved by Real Decreto 1007/2023 (Royal Decree).

Where the confusion comes from

Both systems let the Agencia Tributaria (Spanish Tax Agency) see your invoices before you file any return, both go through its online portal and both are promoted with the same “real time” vocabulary. It is natural to mix them up. But they were not born at the same time, nor to solve the same problem.

The SII (Suministro Inmediato de Información, Immediate Supply of Information) arrived in 2017 to put an end to VAT record books filed after the fact: it reports transactions. VeriFactu arrives in 2027 to put an end to dual-use software: it governs how your software produces the invoice. One looks at the data; the other looks at the tool.

The comparison, point by point

SII VeriFactu
What it regulates Keeping the VAT record books The requirements for invoicing software
Legislation Real Decreto 596/2016 and Orden HFP/417/2017 Real Decreto 1007/2023 and Orden HAC/1177/2024
Since when 1 July 2017 1 January 2027 and 1 July 2027
Who it applies to Businesses that file VAT monthly: large companies, REDEME and VAT groups All other taxpayers concerned: companies, individuals with business activities who pay Spanish personal income tax (IRPF), non-residents with a permanent establishment and pass-through entities (entidades en atribución de rentas)
What is sent Details of the invoices issued and received, plus capital goods and intra-Community transactions Only the record of the invoices you issue
When Four calendar days, not counting Saturdays, Sundays or national public holidays At the moment the invoice is issued, if you opt to submit
Mark on the invoice None: the customer notices nothing Always a QR code; in VERI*FACTU mode, also the wording “Factura verificable en la sede electrónica de la AEAT” or “VERI*FACTU”
What it requires of the software That it can build and send the record books; there is no statement of compliance Declaración responsable (statement of compliance) from the producer for each version (Art. 13)

The underlying difference: the data versus the tool

It is worth pausing here, because it explains everything else.

The SII is a reporting obligation. It cares about which transactions you have carried out, which is why it also includes the invoices you receive: the Agencia Tributaria wants to match your input VAT with the output VAT charged by your supplier. Your software is just a means; the law doesn't go into how it is built inside.

VeriFactu is an obligation on the system. It is not interested in your purchases. What it cares about is that the invoice you issue cannot be altered afterwards: an issuance record chained by a hash, a cancellation record when needed, and no way of deleting anything without leaving a trace. That is why VeriFactu has a manufacturer's statement of compliance and its own penalty regime — Article 201 bis of the Ley General Tributaria (General Tax Act) — and the SII does not.

How to tell which side you are on

The right question is not “does VeriFactu apply to me?” but “how do I file my VAT?”. If you file Modelo 303 (the Spanish VAT return) monthly, you are in the SII. If you file it quarterly, you are not, and then VeriFactu does reach you in 2027.

You file monthly — and are therefore in the SII — if any of these three cases applies:

You may also have joined the SII voluntarily through a census declaration (declaración censal), something done by companies that prefer monthly refunds and accept the four-day discipline in return.

The case nobody plans for: the year you cross the threshold

Here is the real reason for this article. A growing transport company — adding tractor units, winning a big route, taking over a competitor — can go from a turnover of five million to more than six. And then:

  1. In the year you exceed €6,010,121.04, nothing happens straight away.
  2. The following year you become a large company: monthly VAT returns and entry into the SII.
  3. That same day you leave the scope of VeriFactu, through the exclusion in Article 3.3.

And the reverse also happens: if your turnover drops again, you go back to quarterly returns and VeriFactu applies to you once more. This is no laboratory scenario; in a sector with tight margins and contracts that are won and lost whole, crossing the threshold in both directions is completely normal.

The practical consequence is awkward if you have tied yourself to software that can only do one of the two: a change of tax regime should not force you to change your invoicing software.

The question for your supplier: “if I move into the SII next year, what do I have to do?”. If the answer is “switch modules”, “buy something else” or “we'll look at it then”, you already have a problem with a date on it.

What doesn't change in either

It is worth turning the noise down: neither the SII nor VeriFactu touches the essentials of invoicing. You still issue invoices with the same content required by the Reglamento de facturación (Spanish Invoicing Regulation), you still meet the issuing deadlines, you still keep the documents and you still file your tax returns. What changes is when the authorities see it and, in VeriFactu's case, which tool you do it with.

Nor does anything change in the transport documents: the consignment note, the DeCA and the eCMR go their own way — the DeCA with the Ministerio de Transportes (Spanish Ministry of Transport), the eCMR with the CMR Convention and its Additional Protocol — and know nothing about your VAT regime. We cover this in VeriFactu in a transport company.

What your software should handle, whichever side your company is on

  1. Both routes implemented, not one promised. A change of regime should be a setting, not a project.
  2. Received invoices too: the SII requires them, which means your system has to capture the supplier's invoice with its accounting entry date, not just your own invoices.
  3. Retrying and tracking submissions. Four days seem plenty until the portal stops responding on a Friday.
  4. A single source for the data: if the invoice comes from the transport order and the delivery note, what gets sent will be the same as what you have charged.
Giormo has both implemented: the SII with its record books and VeriFactu with its chained records (ready; we switch it on with you, company by company), as well as Italian e-invoicing (fattura elettronica, via the SdI) for companies operating in Italy. How our invoicing works.

Official sources

  • Real Decreto 1007/2023, of 5 December, Regulation on invoicing systems — Article 3.3 (BOE-A-2023-24840). boe.es
  • Real Decreto 596/2016, of 2 December, introducing the SII (BOE-A-2016-11575). boe.es
  • Orden HFP/417/2017, of 12 May, SII technical specifications (BOE-A-2017-5312). boe.es
  • Real Decreto-ley 15/2025 (Royal Decree-Law), of 2 December, first final provision — VeriFactu deadlines (BOE-A-2025-24446). boe.es
  • Agencia Tributaria — Suministro Inmediato de Información (SII). sede.agenciatributaria.gob.es

Frequently asked questions

Can you be in the SII and in VeriFactu at the same time?
No, they are mutually exclusive. Article 3.3 of the Regulation approved by Real Decreto 1007/2023 excludes from VeriFactu's obligations those who keep their VAT record books through the Agencia Tributaria's online portal under Article 62.6 of the Reglamento del IVA (Spanish VAT Regulation), that is, those in the SII.
What does each system report?
The SII reports transactions: it feeds the four VAT record books (invoices issued, invoices received, capital goods and certain intra-Community transactions) with the details of each invoice, both your own and those from others. VeriFactu doesn't look at the invoices you receive: it governs how your software generates, chains and keeps the record of each invoice you issue.
If I exceed the large-company threshold, do I change system?
Yes. Once your turnover exceeds €6,010,121.04 in a calendar year, the following year you move to monthly VAT returns and, with that, into the SII, and you are no longer subject to VeriFactu's obligations. It also works the other way round if your turnover falls, so your software should be able to work both ways.
Which of the two has tighter deadlines?
It depends on what you measure. The SII requires records to be sent within four calendar days, excluding Saturdays, Sundays and national public holidays, including those for invoices received. VeriFactu, in its submission mode, sends the record at the very moment the invoice is issued, but only for the invoices you issue yourself.

Don't let a change of regime change your software

Tell us how you file VAT today and which band your turnover is in, and we'll show you your complete cycle — from transport order to invoice to record book — with both routes covered.

or email us at info@giormo.com