Spain's B2B e-invoicing mandate: key dates and what to prepare

If you run a small business in Spain, you've probably heard more about invoices this past year than in the rest of your working life put together: Verifactu, QR codes, e-invoicing, the "Crea y Crece" law. It's easy for all of it to blur into one vague worry along the lines of "something about my invoicing software has to change, at some point". In fact these are two separate obligations on two separate timetables, and the one covering e-invoices between businesses is about to start its countdown.

This is for you if you invoice other companies or self-employed professionals, or they invoice you — which is nearly everyone. By the end you'll know what has been approved, which dates are firm and which aren't yet, and what you can get ready this autumn without buying anything.

What's approved, and what's still missing

The obligation goes back to 2022. Law 18/2022 on business creation and growth — the "Crea y Crece" law — said every business and professional would have to issue, send and receive electronic invoices when dealing with each other. What it lacked was the regulation explaining how.

That regulation now exists: Royal Decree 238/2026, published in the official gazette (the BOE) on 31 March and in force since 20 April. But "in force" doesn't mean "mandatory" here. The decree itself puts its application on hold until a ministerial order takes effect setting out the technical side of the Tax Agency's public e-invoicing tool. That order is what starts the clock.

The Ministry of Finance put a draft of the order out for consultation in April, and the draft gives 1 October 2026 as its start date. Until the final version appears in the BOE, treat that as the expected date rather than a fixed one — but it's the right date to plan around.

The timetable, counted from that order

The Tax Agency's summary breaks it into three tiers. In brackets is the date you'd get if the order takes effect on 1 October, as the draft says:

• Businesses with more than €8 million in turnover (the VAT "volume of operations") the previous year: twelve months later (October 2027). For their first year under the rule, they'll also have to send a readable PDF alongside every e-invoice.
• Everyone else — the vast majority of small businesses and sole traders: twenty-four months later (October 2028).
• Self-employed individuals and pass-through entities such as comunidades de bienes: they issue and receive in the second tier, but the requirement to report invoice status doesn't apply to them until thirty-six months (October 2029).

One detail rarely gets mentioned, and it reaches you early: you'll start receiving e-invoices before you're required to send them. If your big suppliers — the electricity company, the wholesaler, the leasing firm — are over the threshold, they'll invoice you this way from the first tier. The PDF requirement exists precisely so that businesses that haven't adapted yet can still read them.

The public tool, meanwhile, must be available at least two months before the first tier kicks in. If everything follows the draft, you'll be able to try it properly by late summer 2027 at the latest.

It isn't Verifactu, and it doesn't replace it

This is where most of the confusion lives, so let's take it slowly.

Verifactu is about how your invoicing software records invoices: they can't be deleted or edited without leaving a trace, they carry a QR code and, if you choose that mode, the records are sent to the Tax Agency. After the latest postponement, in Royal Decree-law 15/2025, companies paying corporation tax have until 1 January 2027 and everyone else, the self-employed included, until 1 July 2027.

B2B e-invoicing is about something else: the format the invoice travels in (a structured data file, not a PDF), the channel it travels through and, above all, what happens to it afterwards.

Two rules, two dates. Complying with one doesn't let you off the other. Ideally your software handles both, but that's something to ask, not assume.

What really changes: an invoice's life after you send it

The format is the technical part, and in practice your software provider sorts it out. What falls to you is something else, and it's the whole point of the law: tackling late payment.

Once the rule reaches you, as a customer you'll have to tell each supplier whether you accept or reject their invoice, and let them know once it's been paid in full. You'll also have to report to the Tax Agency's public platform any rejection, the date of full payment and the due date. As a supplier, you'll know where each invoice you've issued stands, and you'll be able to report payments and non-payments too.

In everyday terms: today an invoice goes out, and the next thing you hear is that it's been paid… or not. Under the new system every invoice has a status, and someone in your business has to keep it moving. That isn't technology; it's a process — who checks incoming invoices, who approves them, who marks them as paid, and when.

Two practical points from the draft order. Each invoice will be identified by a unique code built from the issuer's tax ID, series, number and issue date, so your numbering needs to be clean. And the Tax Agency's free tool works through a web form, one invoice at a time, logging in with a digital certificate or Cl@ve. If you issue ten invoices a month, that may be all you need. At two hundred, probably not.

What to prepare this autumn, without spending a cent

1. Find out which tier you're in. Ask your accountant for last year's volume of operations. For most small businesses the answer will be "the twenty-four-month tier", which takes a lot of pressure off.
2. Put three questions to your invoicing software provider, in writing. When will you be Verifactu-ready? Will you issue e-invoices in the format the public platform uses (UBL), and connect to it or to a private platform? How will I manage acceptance and payment statuses from inside the software? If the third answer is vague, make a note of it.
3. Take stock of how invoices reach you today. Email with a PDF attached, paper, supplier portals, WhatsApp. Count how many arrive each month and from how many suppliers. That number decides whether the free web form will do or you need something more.
4. Give the status process an owner. Decide who signs off an incoming invoice and who marks it as paid. If right now that's "whoever remembers", fix that first — law or no law.
5. Clean up your series and customer data. Duplicate numbers, series that change every year for no reason, customers with no tax ID or an outdated company name. In a system where invoices are identified by exactly that data, every mistake is a rejection.

When there's no point rushing

If someone calls this month to sell you "the mandatory e-invoicing platform" with a sense of urgency, be wary. The final order isn't in the BOE yet, the technical specs could still shift and, if you're in the second tier, you have two years. Switching invoicing software now only makes sense if yours was already a headache or won't be ready for Verifactu, which really is just around the corner.

Nor is it worth building custom integrations against the public platform before the final specs are out. What you can automate now, because it doesn't depend on the format, is everything around the invoice: reading the ones that arrive by email and matching them to orders and delivery notes, knowing which are waiting for review, flagging the ones about to fall due and chasing the ones that haven't been paid. When the mandate lands, that work will still be there; only the file will change.

In short: the regulation is approved, the countdown hinges on an order expected on 1 October, and the biggest change for you isn't the file format — it's keeping the status of every invoice up to date.

If today that review-approve-mark-as-paid routine lives in a spreadsheet and in one person's head, now is a good time to put it on a proper footing with process automation, before the calendar does it for you.