Mandatory e-Invoicing (Yes, it’s happening)

by

Spain has officially joined the “no more paper (or dodgy PDFs)” club. Royal Decree 238/2026, approved on 25 March, introduces mandatory electronic invoicing for businesses and professionals (B2B), in line with the “Crea y Crece” Law and the EU’s grand plan to modernise VAT systems.

The aim? A noble trio: boost digitalisation, improve traceability, and perhaps most ambitiously, tackle late payments.

Current situation and what’s next

Although the Royal Decree has been published, nothing dramatic needs to happen just yet, so no need to panic or throw your printer out of the window.

The actual timeline will depend on a forthcoming Ministerial Order (expected before July 2026), which will define the technical details and officially start the clock.

The obligation applies to all B2B (Business-to-Business) transactions. These are deals where one business sells products or services to another business, rather than to individual consumers.

Additionally, certain businesses will need to issue electronic invoices to private individuals if they request or accept them.

Gradual implementation

The rollout will be staggered to give businesses time to adapt:

  • Companies with turnover above €8 million: 1 year from the Ministerial Order.
  • Small and medium-sized enterprises and self-employed: 2 years from the same date.

In practical terms, we are looking at 2027 for larger companies and 2028 for everyone else. So yes, there’s time, but not that much.

Not to be confused with…

Let’s clear up the usual suspects:

  • Facturae: the format used for invoicing public administrations.
  • Verifactu: focuses on how invoices are generated and recorded for tax purposes and ensuring the integrity of billing records to prevent any tampering.

Unlike Verifactu, B2B e-invoicing is about how invoices are exchanged between businesses, not automatically reported to the tax authorities.

What will change?

Quite a lot, actually. Under the new rules, businesses must electronically record the issuance, acceptance, and payment of invoices.

Invoices will need to be:

  • Structured, machine-readable files (not just pretty PDFs).
  • Sent through authorised electronic platforms (public or private).
  • Updated with status information (accepted, rejected, paid—no ghosting allowed).

Companies will be able to use:

  • Interconnected private platforms, or
  • A free public platform from the Spanish Tax Office (though not expected until 2027).

And yes, this means proper software will be essential. Excel and wishful thinking won’t cut it anymore.

Also worth noting, once this system is in place, PDFs and paper invoices between businesses will no longer be valid. It is the digital way or the highway.

Not everything falls under this regime:

  • Simplified invoices (tickets) issued to private individuals.
  • Invoices to non-Spanish companies.

What should you be doing now?

No immediate action is required, but this is not the time for complacency either:

  • Prioritise adapting to Verifactu (deadlines are closer, 2027).
  • Keep an eye on the Ministerial Order (this is the real starting gun).
  • Choose invoicing software that can handle both systems, future you will be grateful.

Mandatory e-invoicing represents a significant shift in how businesses operate. While the transition will be gradual, getting ahead of the curve will make life considerably easier, and avoid last-minute headaches (the accounting equivalent of doing your tax return the night before).

Further information on Spanish tax changes for 2026 can be found here.

Spence Clarke specialises in the provision of Spanish tax, accounts, law and labour services, mainly to foreigners with interests in Spain. Our cross-border knowledge helps clients adapt to the Spanish system with the minimum of doubt and disruption. If you have any questions about this article or any other matter contact us, with no obligation, to see how we can help you.