Fiscal subject related
Spain has introduced a temporary opportunity for companies to leave the SII (Suministro Inmediato de Información) system after the government postponed the VERI*FACTU invoicing software mandate until 2027.
Many businesses voluntarily joined SII in 2025 in order to avoid the technical requirements of the VERIFACTU Ordinance, which applies to invoicing software and requires secure, traceable invoice records that can be accessed by the tax authorities. However, when the government unexpectedly delayed VERIFACTU in December 2025, those companies found themselves locked into SII for 2026 because the normal deadline to exit SII had already passed.
To address this situation, Royal Decree-Law 16/2025 introduced an extraordinary opt-out period from 26 December 2025 to 31 January 2026. During this time, taxpayers who joined SII voluntarily can renounce their participation by submitting Form 036 or 037. The withdrawal will apply retroactively from 1 January 2026. This option does not apply to taxpayers that are legally required to use SII. This option is only available to taxpayers who joined the SII on a voluntary basis and does not apply to taxpayers mandatorily subject to the SII.
The new rules also allow eligible companies to deregister from the Monthly VAT Refund Register (REDEME) if they joined it in order to enter SII.
Although the business obligation to use VERIFACTU has been postponed until 2027, the rules for software providers remain in force. Since 29 July 2025, invoicing software that is not compliant with the VERIFACTU technical standards can no longer be sold in Spain. This applies both to commercial software vendors and to companies that develop or share their own invoicing systems within a corporate group.
The VERI*FACTU Ordinance regulates the technical integrity and traceability of invoicing software, but it does not cover mandatory B2B e-invoicing or general invoicing obligations, which will be regulated separately in future legislation expected in 2026.
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