Spain's e-invoicing rules, untangled: Crea y Crece, Verifactu, and where Peppol fits
Spain is building two separate e-invoicing systems on top of an existing B2G one. Here is what is in force, what is still pending, and what a Stripe user actually needs to do.
Spain is harder to summarise than most EU countries because it is running two different reforms at once, on separate timelines, and neither is pure Peppol. If a Spanish customer or your accountant has mentioned Crea y Crece, Verifactu, or FACe and you bill through Stripe, the useful first step is to separate the three and work out which, if any, binds you today.
The three things people mean by "Spanish e-invoicing"
FACe — B2G, already in force. Selling to Spanish public bodies has required structured e-invoices since 2015, submitted in the national Facturae XML format with a qualified electronic signature through the FACe platform. If your customer is a government body, this is the rail, and it has been mandatory for a decade.
Verifactu — billing-software rules, near-term. This is not an e-invoicing mandate at all; it governs how your invoicing software records invoices. Verifactu requires tamper-proof, chained records with a QR code and a digital fingerprint, so invoices cannot be altered after the fact. It applies to corporate taxpayers from 1 January 2027 and to the self-employed from 1 July 2027. Businesses already inside the SII real-time reporting system are exempt, because they report to the tax authority live anyway.
Crea y Crece — the B2B e-invoicing mandate, still pending. Law 18/2022 laid the foundation for mandatory structured invoicing between Spanish businesses. Its implementing Royal Decree 238/2026 was published on 31 March 2026, but the mandate is not live: the deadlines only start counting once a Ministerial Order takes effect. As of mid-2026 that Order is still a draft — published for consultation on 16 April 2026 — with its operational start pencilled in for around 1 October 2026.
On the currently anticipated schedule, the B2B obligation then reaches companies with turnover above 8 million euros on 1 October 2027, and everyone else, including the self-employed, on 1 October 2028. Treat all of these dates as provisional until the final Order is published, and confirm the current position with the Agencia Tributaria.
How this relates to Peppol, and how it does not
Spain is building a national system, not adopting Peppol wholesale. The model pairs a public platform run by the tax authority with private exchange platforms that must interoperate, and every issued invoice is also reported to the state. That reporting hub makes it closer in spirit to Poland's KSeF than to the direct four-corner exchange Belgium uses.
There is a real Peppol connection, though. Crea y Crece admits four structured syntaxes — UBL, CII, EDIFACT, and Facturae — all aligned with the European standard EN 16931, which is the same standard the Peppol BIS Billing 3.0 profile builds on. If you want the distinction between the two, see BIS 3.0 versus EN 16931. So a compliant Peppol UBL invoice speaks the right underlying language, even though Spain wraps it in national reporting and status-tracking rules that Peppol alone does not cover. One of those rules: recipients must report each invoice's status, including rejection and the payment date, within a few working days.
What a Stripe user should do
Two honest points first. Verifactu and Crea y Crece are not yet in force, so there is likely nothing you must do this quarter — but the direction is fixed, so it is worth getting Peppol working while the pressure is low. And the treatment of foreign businesses without a permanent establishment in Spain is not yet settled in the published texts, so if you sell into Spain from outside it, watch the final Ministerial Order rather than assume you are in or out.
Where Peppol is the right channel — Spanish customers who accept it, and the many other EU countries you invoice — Peppost adds the delivery layer that Stripe does not have. It reads the invoices and credit notes you have already finalised in Stripe, generates UBL on the BIS Billing 3.0 profile, attaches the original Stripe PDF, checks the recipient against the Peppol directory before any credit is spent, and dispatches through a certified access point. No subscription, one credit per send, credits that never expire, and free sends on a new account to rehearse in Stripe test mode. The credits and billing guide covers the pricing mechanics and the FAQ the rest.
Spain will get stricter on a schedule that is still being drawn. The move that holds up regardless of how the final Order lands is to know which of its three systems touches you, and to have Peppol delivery ready for the part that does.