Businesses that pay tax to the regional (foral) tax authorities of the Basque Country and Navarre do not apply VeriFactu. In Álava, Bizkaia and Gipuzkoa, TicketBAI applies, and in Bizkaia it is part of the Batuz strategy. Navarre follows the rules of its own Foral Tax Authority. Anyone taxed under the common territory regime, even if they operate there, is subject to the national system from 2027.
Who applies TicketBAI, Batuz or VeriFactu depending on the competent tax authority
What determines the system is the competent tax administration, not the address of the office or of the client. Real Decreto 1007/2023, the regulation governing national invoicing software systems, expressly excludes taxpayers of the foral tax authorities. That exclusion covers the Basque Country, where TicketBAI applies, and Navarre.
To find out which tax authority is yours, you need to look at the Concierto Económico (Basque Country) or the Convenio Económico (Navarre). These rules allocate competence based on tax residence and, in certain cases, on where the transactions take place. If your business operates in several territories, your tax adviser should confirm which administration is competent before you choose any software.
The rest of Spain falls under the national regulation, including the Canary Islands, Ceuta and Melilla. The current dates published in the BOE, Spain's official gazette (Real Decreto-ley 15/2025), are these:
- 1 January 2027: Corporate Income Tax (Impuesto sobre Sociedades) taxpayers.
- 1 July 2027: freelancers and sole traders, joint ownerships (comunidades de bienes) and civil partnerships without legal personality.
The Ministry of Finance has announced its intention to postpone them to October 2028. That postponement has been announced but is still pending publication in the BOE. You can check the details by type of taxpayer in the VeriFactu mandatory dates calendar.
Comparison table: TicketBAI and Batuz versus VeriFactu
All three systems pursue the same goal: invoicing software must not allow sales to be altered or hidden without leaving a trace. They differ in who regulates them and in how the information reaches the tax administration.
| Aspect compared | VeriFactu (common territory) | TicketBAI (Álava, Bizkaia, Gipuzkoa) | Batuz (Bizkaia) |
|---|---|---|---|
| Who regulates it | Ministry of Finance and AEAT | Each Basque provincial council (diputación foral) | Bizkaia Foral Tax Authority |
| Main regulation | Real Decreto 1007/2023 and Orden HAC/1177/2024 | Each territory's own foral regulations | Bizkaia foral regulations |
| Submission to the administration | Submission to the AEAT or non-submission mode with more requirements | Each invoice submitted to the foral tax authority | TicketBAI plus a ledger of economic transactions |
| Elements on the invoice | Chained SHA-256 hash and QR code | TicketBAI identifier and QR code | Those of TicketBAI |
| Penalty regime | Article 201 bis of the Ley General Tributaria | Own foral regulations | Own foral regulations |
The national system records each invoice with a registration record and, where applicable, a cancellation record. Each record carries a SHA-256 hash chained to the previous one. TicketBAI also chains invoices and adds a QR code, but it follows its own technical specifications. Software built for only one system does not automatically comply with the other.
Batuz is not a system separate from TicketBAI. It is Bizkaia's comprehensive strategy, which combines TicketBAI with keeping a ledger of economic transactions with its foral tax authority.
Navarre and VeriFactu: the Navarre Foral Tax Authority sits outside the national system
Taxpayers of the Navarre Foral Tax Authority are not bound by the 2023 national regulation, because Navarre has its own legislative competence. This does not mean they can invoice without controls. Navarre applies its own regulation on invoicing systems, and its requirements and deadlines are set by the Foral Tax Authority, not by the Spanish Tax Agency (AEAT).
For a business in Navarre, the practical step is to check with the Navarre Foral Tax Authority or with its adviser what its regulations require today. It is advisable to choose software that specifically declares compliance with those regulations. Software meeting the national requirements is not, on its own, adapted to Navarre.
3 mixed cases of businesses operating in the Basque Country or Navarre
The most common question is not about the purely foral business, but about those with clients, offices or partners on both sides.
- SL (limited company) with tax residence in Madrid selling to clients in Bizkaia. It is taxed in the common territory, so it applies the national system from 1 January 2027. Selling to Basque clients does not make it a foral taxpayer.
- Freelancer with tax residence in Gipuzkoa invoicing companies in Valencia. Their competent tax authority is the foral one, so they apply TicketBAI. The location of their clients does not change the system they must use.
- Business operating in both the common territory and a foral territory. The Concierto or Convenio Económico determines which administration is competent in each case. It may need software compatible with more than one system, and it is advisable to confirm this with an adviser.
In every case, the AEAT does not approve or certify invoicing software. At national level, the only mechanism is the manufacturer's responsible declaration (declaración responsable), which was due to be available from 29 July 2025. If you believe you are outside the national system, review the scenarios in the guide to freelancers exempt from VeriFactu.
B2B e-invoicing for foral businesses: a separate obligation
Being outside the national system because you are taxed by a foral authority does not, on its own, exempt you from B2B electronic invoicing. They are different obligations. B2B e-invoicing stems from Ley 18/2022 (Ley Crea y Crece) and regulates the format and exchange between businesses. Anti-fraud systems regulate the software that generates and stores the records.
The B2B e-invoicing deadlines run from 6 October 2026, the date Orden HAC/1028/2026 came into force:
- 6 October 2027: for those whose turnover exceeded 8 million euros in the previous year.
- 6 October 2028: for all other businesses and professionals.
The accepted formats are UBL, CII, EDIFACT and Facturae. See how it affects you in the electronic invoicing guide for freelancers.
Frequently asked questions
Does a business in the Basque Country have to use VeriFactu?
A business in the Basque Country that is taxed by its foral tax authority does not use VeriFactu: it applies TicketBAI, integrated into Batuz if it is based in Bizkaia. It would only be subject to the national system if its competent administration were the AEAT, under the Concierto Económico.
What is the difference between TicketBAI and Batuz?
TicketBAI is the invoicing control system of Álava, Bizkaia and Gipuzkoa. Batuz is Bizkaia's strategy, which incorporates TicketBAI and adds a ledger of economic transactions kept with the Bizkaia Foral Tax Authority. A business in Bizkaia complies with both within the same framework.
Are businesses in Navarre required to use VeriFactu?
Businesses taxed by the Navarre Foral Tax Authority are not required to use VeriFactu, because the national regulation excludes foral taxpayers. They must comply with Navarre's own rules on invoicing systems, whose requirements and deadlines are set by the Foral Tax Authority itself.
Is software built for TicketBAI enough to comply with VeriFactu?
Software built for TicketBAI does not automatically comply with VeriFactu, because each system has its own technical specifications. If a business operates under both administrations, it needs software that declares compliance with both systems, with its responsible declaration in the national case.
If you are unsure which administration applies to you or whether your current software leaves you exposed, you can use Fakturia's free VeriFactu risk diagnosis. It takes 2 minutes and helps you find out whether you must comply with the national system and from what date.