If we issue electronic invoices to the administration and we are obligated to use SII, are we already complying without using VERI*FACTU?

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Not completely.

The situation is:

  • SII implies that you communicate VAT data to the AEAT (Spanish Tax Agency) in near real-time.
  • Electronic invoicing to public administration (B2G) is a specific obligation based on the recipient.
  • But the VERI*FACTU regulation establishes additional requirements on how your internal IT system must function.

Therefore:

  • You are complying with your sending and communication obligations, but not necessarily with the internal registration and integrity requirements of VERI*FACTU.
  • Therefore, even if you are in SII and use electronic invoicing, you must adapt your software to VERI*FACTU before January 1st or July 1st, 2026, as applicable.