Spain has introduced an exceptional measure allowing companies to renounce voluntary participation in SII following the postponement of VERIFACTU. The change was introduced through Royal Decree-Law 16/2025 and applies to businesses that joined SII specifically to benefit from the VERIFACTU exemption.
This temporary window addresses an unintended consequence of the VERI*FACTU delay, which left some taxpayers locked into SII despite the original rationale for opting in no longer applying. The postponement itself is part of a broader adjustment of Spain’s e-invoicing roadmap, as explained in Spain pushes back e-invoicing go-live date.
Why SII and VERI*FACTU became linked
Under the VERIFACTU framework, companies participating in SII are exempt from certain VERIFACTU obligations. This connection led many businesses to voluntarily enrol in SII during 2025 as a way to avoid additional compliance requirements linked to VERI*FACTU.
This exemption mechanism sits within Spain’s wider effort to align its national e-invoicing and reporting frameworks with European standards, a direction previously outlined in Spain aligns B2B e-invoicing standards with EU requirements.
The timing issue for voluntary SII participants
The standard deadline to renounce SII participation is November of the preceding year. By the time the VERI*FACTU postponement was confirmed in December 2025, that deadline had already passed.
As a result, companies that had joined SII purely for VERIFACTU reasons were unable to exit the regime through the normal process, even though the regulatory context had shifted. The broader implications of the VERIFACTU delay, now extending the timeline until 2027, are explained in more detail in VERIFACTU e-invoicing in Spain delayed until 2027.
What the transitional rule allows
Royal Decree-Law 16/2025 introduces a specific transitional solution to this issue.
Companies that voluntarily opted for electronic VAT book maintenance via the Spanish tax authority’s electronic platform are granted an extraordinary opportunity to renounce SII participation outside the usual deadline.
The key elements of this measure are:
- An exceptional renunciation window running from 25 December 2025 to 31 January 2026
- The option applies only to taxpayers who joined SII on a voluntary basis
- Companies subject to mandatory SII obligations are explicitly excluded
What this means for companies
For businesses that joined SII solely to obtain relief from VERIFACTU requirements, this measure restores flexibility. It allows them to reassess their reporting setup in light of the revised VERIFACTU timeline and decide whether continued SII participation still delivers sufficient value.
At the same time, the narrow scope and limited timeframe mean that companies need to act quickly and confirm their eligibility before initiating any changes.
Points to consider before renouncing SII
Before making use of this extraordinary window, companies should assess:
- Whether SII still provides operational or compliance benefits beyond VERI*FACTU
- The impact of leaving SII on VAT reporting processes and system integrations
- How future VERI*FACTU milestones may affect their longer-term compliance approach
This update illustrates how closely connected Spain’s digital VAT initiatives have become and how changes in one programme can have direct consequences for another. Careful evaluation remains essential when navigating these overlapping obligations.
