Mandatory B2B E-Invoicing in Spain: What to Do

Mandatory electronic invoicing between businesses in Spain has become one of those conversations where everyone has a different date in mind. The confusion has a concrete cause: it is not one obligation, it is two, with different timetables and different purposes, and they sound alike.

This article separates the two, explains what applies to you today and why this change is the best opportunity you will get to automate invoicing. If the cost side is what interests you, we have a separate article on automating supplier invoices.

1The difference between Verifactu and e-invoicing

The practical consequence of this table matters: you can be perfectly up to date with Verifactu and still be unable to issue a structured electronic invoice when the other obligation arrives. They are two projects, even though they touch the same document.

2Where Verifactu fits

Verifactu does not change the invoice format: it requires the program you issue invoices with to chain its records, prevent them from being altered without a trace and print a QR code that lets the invoice be checked. Royal Decree-Law 15/2025, the rule's second postponement, pushed the obligation back to 1 January 2027 for Corporate Income Tax payers and 1 July 2027 for everyone else. As it arrives before B2B e-invoicing, it is usually the first front.

3Mandatory B2B e-invoicing: dates and requirements

The Crea y Crece Act requires all businesses and professionals to issue, send and receive electronic invoices in transactions with one another. The missing regulation, Royal Decree 238/2026, was published in the official gazette on 31 March 2026 and specifies what those invoices must be: a structured file that follows the European standard EN 16931, in UBL, CII, EDIFACT or Facturae. A PDF sent by email does not comply.

The deadlines do not run from the royal decree but from the entry into force of the ministerial order governing the Spanish tax authority's public invoicing solution: twelve months for businesses whose volume of operations exceeded eight million euros in the previous year and twenty-four months for everyone else. The draft order sets that entry into force at 1 October 2026, which is where 1 October 2027 and 1 October 2028 come from. Until the order is published in the official gazette these are expected dates: if it comes into force later, both move back by the same amount, so confirm them before you finalise a plan.

To issue and receive invoices you can use a private platform or the free public solution the Spanish tax authority is preparing. Either way, a copy of every invoice reaches the tax authority.

There is a second component that gets discussed less and carries real operational implications: the obligation to report the status of received invoices, meaning their acceptance or rejection and their full actual payment, each with its date and within a maximum of four working days. That turns invoice reception into a process with obligations of its own, not just an inbox where documents land.

4Why this is the best moment to automate

Adapting purely to comply means doing half the work and keeping the worse half. Here are the concrete reasons; if you want to put figures on them, we explain how to calculate the ROI of automating a process.

5Where to start, in order

• Check your issuing software. If it cannot demonstrate compliance, that is the absolute priority and everything else waits.
• Inventory how invoices come in and go out. How many channels, how many formats, how many suppliers. It is the basis of every later decision.
• Separate issuing from receiving. They are two projects with different rules and different difficulty. Merging them into one scope usually ends badly.
• Design for coexistence. For a good while you will receive structured invoices and PDFs at the same time. The flow must accept both inputs without duplicating work.
• Leave status reporting ready even if it is not yet enforceable. Allowing for it in the design is cheaper than bolting it on later.

For the current state of the rules and the technical requirements, the reference is the electronic office of the Spanish tax authority, the Agencia Tributaria. This article is informative and does not replace tax advice: deadlines have changed several times and should be checked with your adviser before making decisions.

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