Mandatory e-invoicing in Spain: deadlines and requirements

Real Decreto 238/2026, published in the BOE on 25 March 2026, is already in force. Every company and self-employed professional invoicing other businesses will have to issue and receive invoices in structured electronic format. This is not about emailing a PDF: the rule requires a machine-readable file, with full traceability from issue to payment.

The obligation covers all B2B transactions (between businesses and professionals) that are tax resident in Spain. Transactions with final consumers (B2C) fall outside it. The stated aim of Ley 18/2022, the Spanish Crea y Crece act behind this regulation, is twofold: to cut late payment between businesses and to digitalise the Spanish economy.

What is mandatory e-invoicing and when does it take effect?

A mandatory electronic invoice is a digital document in structured format — not a PDF or a scanned image — that is created, transmitted and stored electronically. It must follow the European semantic model EN16931 and use one of the four formats the rule accepts.

RD 238/2026 came into force on 20 April 2026. The effective obligation to issue electronic invoices does not start automatically, though: it depends on the publication of a ministerial order from the Spanish Ministry of Finance activating the public platform run by the Spanish Tax Agency (AEAT). Once that order is published, the adaptation deadlines start to run.

Current estimates put publication of the ministerial order in the second half of 2026, which would mean the first effective obligation falls between the end of 2027 and the start of 2028 for large companies.

Adaptation deadlines: timetable by company size

The deadlines run from publication of the ministerial order. The system is phased:

In addition, for the first 12 months after their obligation starts, large companies must send a readable PDF copy with every electronic invoice, to make the transition easier for recipients that are not yet adapted.

Do you need to plan your company's transition? Our specialist consultancy team can design a tailored transition plan.

Technical requirements: formats, platforms and the AEAT public service

Accepted formats

RD 238/2026 accepts four syntaxes for electronic invoices, all based on the European standard EN16931:

• UBL (Universal Business Language) — the format preferred by the AEAT public platform
• CII (Cross-Industry Invoice, UN/CEFACT)
• EDIFACT (invoice messages)
• Facturae — the traditional Spanish format for invoicing public bodies (B2G)

Two transmission channels

Invoices can be sent through:

• The AEAT public platform: free, open to every company, using UBL syntax. Ideal for self-employed professionals and micro-companies that would rather not pay for a private platform.
• Private invoicing platforms: they must guarantee interoperability with other platforms and send a faithful copy of every invoice to the AEAT public repository at the same time.

Traceability obligations

Every electronic invoice must carry a unique code made up of the issuer's NIF (Spanish tax number), the invoice number and series, and the date of issue. The recipient has a maximum of 4 working days to notify commercial acceptance or rejection of the invoice, and the same period to report full payment.

Who is covered and who is exempt?

Covered: every business and professional issuing invoices to other businesses and professionals that are tax resident in Spain. That includes the self-employed, SMEs and large companies, whatever the sector.

Exempt from B2B e-invoicing:

• Transactions with final consumers (B2C)
• Simplified invoices (except "qualified" ones)
• International transactions with recipients outside Spain
• Electricity and gas operators under specific schemes
• Transactions settled through the IATA clearing system

One distinction matters: the exemption applies to the transaction, not to the company. An SME can be covered for its sales to other businesses and exempt for its sales to individuals.

Verifactu and e-invoicing: are they the same thing?

No. This is one of the most common confusions. They are separate obligations with different legal frameworks:

In practice, your invoicing software will have to meet both sets of rules: compatible with Verifactu (integrity and record-keeping) and with B2B e-invoicing (structured format and exchange).

Not sure how these obligations affect your company? Talk to our team and we will help you assess your position.

Penalties for non-compliance and late payment control

Penalties

The penalty regime provides for fines of up to €10,000 per offence for companies that fail to issue electronic invoices when required. Breaches of integrity and traceability can reach €50,000, and breaches of the privacy of the data held in the invoices up to €60,000.

Late payment control

The Crea y Crece act sets a maximum payment period of 60 days. Electronic invoicing lets the AEAT monitor actual payment times. Companies that miss that deadline will:

• Lose access to public grants
• Be barred from acting as partner companies with public bodies
• Appear on the list published by the Spanish late payment observatory

This is one of the least discussed but most significant effects of the rule: electronic invoicing becomes an effective tool for controlling late payment, a problem that hits SMEs and the self-employed hardest.

How to adapt: steps and funding available

Adaptation plan in 5 steps

1. Audit your current invoicing: work out what share of your invoices is B2B and what share is B2C
2. Assess your software: check whether your invoicing program supports Verifactu and the electronic formats required (UBL, Facturae)
3. Choose a transmission channel: the AEAT public platform (free) or a private platform (more features, at a cost)
4. Adapt internal processes: set up the reporting of invoice status (acceptance, rejection, payment) within the 4 working day deadline
5. Train the team: make sure administrative and accounting staff know the new invoicing flow

Funding to pay for the transition

There are no grants specifically for electronic invoicing, but digitalising your invoicing processes can be funded through current grant programmes. Kit Consulting, for example, includes digital advisory work covering the roll-out of e-invoicing tools in SMEs.

Investment in invoicing software is also a deductible expense under Spanish corporate income tax (Impuesto sobre Sociedades), and in many cases it can qualify for accelerated depreciation for SMEs.

What is the next step?

The clock is running. Although the deadlines depend on the pending ministerial order, companies with turnover above €8 million could have to comply from the end of 2027, and everyone else from the end of 2028.

Getting ahead has clear advantages: avoiding penalties, keeping access to public grants and improving collections. At Tecnocim Innova we can help you plan the transition, assess your current software and connect the work with the funding available in Spain.

Contact us for an initial review with no obligation.