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Mandatory B2B e-invoicing in Spain: what is actually known

Published on · Reviewed on · Taxes · 6 min read

E-invoicing between businesses is going to be mandatory in Spain. It is in a 2022 law and a 2026 royal decree. But the date from which the deadline starts running depends on a ministerial order, and as of 26/09/2026 that order has not been published in the BOE (Spain's official gazette). This article separates what the rules say from what gets repeated online.

What the law says

The obligation comes from Law 18/2022 on business creation and growth, known in Spain as the «Crea y Crece» law. Its article 12 amends Law 56/2007 to say that «Todos los empresarios y profesionales deberán expedir, remitir y recibir facturas electrónicas en sus relaciones comerciales con otros empresarios y profesionales» (all businesses and professionals must issue, send and receive electronic invoices in their dealings with other businesses and professionals). It adds that issuer and recipient «deberán proporcionar información sobre los estados de la factura» (must report the status of the invoice): whether it is accepted, rejected or paid.

The law did not set a specific date. It left the start for when the implementing regulation was approved, with one year's margin for businesses invoicing more than eight million euros a year and two years for everyone else (final provision eight).

Royal Decree 238/2026

That implementing regulation is Royal Decree 238/2026, published in the BOE on 31/03/2026. It sets out what the invoices must look like, the platforms that carry them and the information about their payment. It came into force twenty days after publication, but that does not mean invoicing this way is already compulsory.

Its fourth final provision says that its practical application is deferred, and counts the deadlines «desde la entrada en vigor de la orden ministerial» (from the entry into force of the ministerial order) that has to set up the Tax Agency's public e-invoicing solution:

  • 12 months after that order, for businesses and professionals whose volume of operations exceeded €8 million in the previous year.
  • 24 months after, for everyone else. This covers almost every self-employed online seller.

The Spanish Tax Agency (AEAT) says the same in its note of 31/03/2026, and adds that its public solution must be available «al menos dos meses antes de la primera aplicación efectiva» (at least two months before the decree first applies).

The ministerial order: the missing piece

We searched the BOE on 26/09/2026 and found no published order setting up the public e-invoicing solution. Until it is published and comes into force, the 12- and 24-month periods do not start running.

So any specific date you read today for mandatory e-invoicing is an estimate, not a date from the rules. Once the order comes out, you will find your date by adding 24 months (or 12, if you are above €8 million) to its entry into force.

Who it affects and who it doesn't

The royal decree applies to the invoices you issue when your customer is a business or professional with its seat, permanent establishment or address in Spain (article 3). For an online store this has two sides:

  • Your sales to consumers are not included. The obligation is between businesses and professionals. If you sell to end consumers, those sales fall outside this royal decree.
  • Your sales to Spanish businesses and self-employed people are included, for example if you sell wholesale to other shops.
  • Your purchases count too. Spanish suppliers who invoice you will send you electronic invoices, and you will have to report their status.

There is one important exception: simplified invoices (receipts) do not have to be electronic, except those that carry the business customer's details, which the regulation calls «facturas simplificadas cualificadas» (qualified simplified invoices, article 4 of the royal decree).

What the invoices will look like

A PDF is not enough. The royal decree requires a «mensaje informático de carácter estructurado» (a structured electronic message) that follows the European standard EN16931 and uses one of the accepted formats, such as UBL or CII (article 7). In other words, a file that software can read field by field.

They can be sent in two ways, or a mix of both (article 5):

  • Through private exchange platforms, which will have to connect to each other.
  • Through the Tax Agency's public solution, which will also keep a copy of every invoice. The royal decree says its use «tendrán carácter gratuito para los usuarios» (will be free for users, article 11).

Reporting acceptance and payment

The change that will affect day-to-day work the most is the invoice status. Whoever receives an invoice will have to say whether they accept or reject it and when they paid it (article 10). Full payment is reported to the public solution «en un plazo máximo de 4 días naturales» (within 4 calendar days at most) from the payment date, not counting Saturdays, Sundays and national public holidays (article 12).

For self-employed people with a volume of operations up to €8 million, the duty to report these statuses gets an extra year: it applies twelve months after the royal decree starts to apply to them, and until then it is voluntary (third transitional provision).

How does it relate to Verifactu?

They are two separate obligations that overlap. Verifactu is about your invoicing software keeping a tamper-proof record of every invoice. For the self-employed, systems must be adapted before 01/07/2027 (Royal Decree-law 15/2025). E-invoicing is about the format of the invoice and how it is sent to another business.

The link is in the royal decree's definition: a mandatory electronic invoice has to come from software adapted to article 29.2.j) of the General Tax Act, which is the article the Verifactu regulation develops (Royal Decree 1007/2023). We explain it in Verifactu for online stores.

What you can do now

  • Don't worry about dates that don't exist. Until the order is published, no day has been set.
  • Check how many of your invoices go to businesses. If almost all your sales are to consumers, the change will mostly affect the invoices you receive.
  • Ask your invoicing software whether it plans to issue structured invoices and connect to platforms or to the public solution.
  • Talk to your accountant (gestor) once the order is out, to confirm your exact date.

To see your invoices and your numbers in one place, open the demo or try Plentia free for 14 days, no card needed.

Sources

This article explains the general rule with its official sources. Your case may have exceptions: it doesn't replace your accountant.

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