If you search "mandatory e-invoicing Spain" online, you'll find dozens of articles that mix rules, deadlines, and concepts in confusing ways. The reality is that Spain does not have a single e-invoicing obligation, but several, each with its own law, its own deadlines, and its own scope.
This article lays out the full picture: from what counts as an electronic invoice to the specific deadlines set by each regulation, including who is exempt and who is not. Everything updated with RDL 15/2025 and the draft Ministerial Order of April 2026.
What exactly is an electronic invoice?
An electronic invoice is not simply a PDF sent by email. For a document to qualify as an electronic invoice under the law, it must meet two conditions: it must have been generated by electronic means and it must be in a structured format readable by machines, such as XML, UBL, or Facturae.
The distinction matters. A PDF, a Word file, or a scanned image contains data a person can read, but that software cannot automatically interpret. An XML or UBL file, by contrast, structures the data (issuer, recipient, taxable base, VAT, total amount…) so that any billing software can process it without manual intervention.
Understanding this helps explain why Spanish regulations refer to structured electronic format rather than simply "digital invoice." The Tax Agency's goal is twofold: automate fiscal verification and reduce errors in the business-to-business invoicing chain.
E-invoicing vs. Verifactu: two regulations you should not confuse
This is probably where the most confusion arises. When people talk about "mandatory e-invoicing," they usually lump together two legally independent concepts:
Verifactu (Royal Decree 1007/2023)
Regulates how the software that generates invoices must work. It says nothing about the format of the final document: what it requires is that the software guarantees the integrity, immutability, and traceability of every invoicing record. It also mandates a QR code verifiable by the AEAT on each invoice issued.
In short: Verifactu governs the invoicing engine, not the envelope the invoice is delivered in.
Crea y Crece Law (Law 18/2022)
Regulates the exchange format of invoices between businesses and professionals. It mandates that B2B invoices be issued and received in a structured electronic format, via the AEAT's public solution or accredited private platforms.
In short: Crea y Crece governs the envelope and the delivery channel, not necessarily the internal workings of the software.
They are different laws with different timelines. But in practice, most businesses will need to comply with both throughout 2027 and 2028.
Invoicing the public sector: an obligation that already exists
While B2B e-invoicing still has future dates, there is one scenario where the obligation has been in force for years: invoices issued to public administrations (B2G).
Since January 2015, Law 25/2013 requires all companies (SA, SL, UTE, permanent establishments of non-residents) to submit their invoices to the public sector in electronic format — specifically in Facturae (XML) — through the FACe platform or equivalent gateways of each administration.
For self-employed individuals, this obligation kicks in for contracts above €5,000, although each administration may set its own exemption thresholds.
If your business works with public administrations and you are still sending paper or PDF invoices, the breach is not something that lies ahead — it is already happening.
Verifactu: billing software under the Tax Agency's microscope
Law 11/2021 (Anti-Fraud Law) and Royal Decree 1007/2023 introduce a new concept in Spain: that billing software itself must meet verifiable technical requirements. It is no longer enough for a program to issue correct invoices; now it must guarantee that records cannot be retroactively altered, that each invoice generates a hash chained to the previous one, and that it includes a QR code so the Tax Agency can verify its authenticity.
The system is called Verifactu, and its timeline, amended by RDL 15/2025, is as follows:
- Software vendors (SIF): were required to have their products adapted by July 2025. This obligation is already active.
- Companies (SA, SL, and entities subject to corporate income tax): from 1 January 2027.
- Self-employed individuals and other taxpayers: from 1 July 2027.
A relevant detail: companies enrolled in the Immediate Supply of Information (SII) — generally those with annual turnover above €6 million — are excluded from Verifactu, since the AEAT already receives their records in near real-time. However, the SII does not exempt them from the future B2B e-invoicing obligation.
E-invoicing between businesses: the Crea y Crece Law
The final piece of the puzzle is Law 18/2022 (Crea y Crece), which mandates the exchange of invoices in a structured electronic format for all B2B transactions between businesses and professionals established in Spain.
On 16 April 2026, the Ministry of Finance published the draft Ministerial Order that specifies the public e-invoicing solution. This draft was the missing regulatory step. According to its contents:
Who does it affect?
- All companies (SA, SL, cooperatives, associations, foundations) in their transactions with other professionals.
- All self-employed individuals and professionals who invoice other businesses or self-employed workers.
Who is NOT affected?
- Sales to individual consumers (B2C): a restaurant, a clothing store, or a hair salon that only invoices private individuals falls outside this regulation.
- Simplified invoices and receipts: generally excluded, except for "qualified simplified invoices."
- Transactions where either party is not established in Spain: both issuer and recipient must be established on Spanish territory.
Accepted formats and channels
The Spanish system will be hybrid: companies can use the AEAT's free public solution, accredited private platforms, or both simultaneously. The reference format is UBL (Universal Business Language), although Facturae and other structured electronic formats are also accepted.
Additionally, RD 238/2026 requires communicating the status of each invoice (received, accepted, rejected, paid) within a maximum of four calendar days.
Implementation deadlines
The Ministerial Order would enter into force on 1 October 2026. From that point:
- Companies with turnover above €8 million: 12 months → 1 October 2027.
- All other businesses and professionals: 24 months → 1 October 2028.
These dates will be definitively confirmed upon publication of the Order in the Official State Gazette (BOE).
Full timeline: who must do what and when
For the complete picture at a glance:
| Regulation | Who is affected | Deadline |
|---|---|---|
| Law 25/2013 (B2G) | Companies invoicing the public sector | January 2015 (in force) |
| RD 1007/2023 (Verifactu) | Billing software vendors | July 2025 (in force) |
| RD 1007/2023 + RDL 15/2025 | Companies (corporate tax) | 1 January 2027 |
| RD 1007/2023 + RDL 15/2025 | Self-employed and other taxpayers | 1 July 2027 |
| Law 18/2022 (Crea y Crece) | Companies with turnover >€8M | 1 October 2027* |
| Law 18/2022 (Crea y Crece) | All other businesses and professionals | 1 October 2028* |
* Subject to confirmation upon publication of the Ministerial Order in the BOE.
What if I don't comply? Fines and real consequences
The penalty regime depends on which obligation is breached. Here are the most relevant ones:
For not using Verifactu-compliant software
Article 201 bis of the General Tax Law is clear:
- Manufacturing or selling non-compliant software: €150,000 per fiscal year per type of system.
- Using non-compliant software as a business: €50,000 per fiscal year.
A detail many overlook: if your software vendor has abandoned maintenance and the product no longer complies with the regulation, the liability falls on the business using it, not on whoever sold it originally.
For not issuing B2B electronic invoices
The Crea y Crece Law sets fines of up to €10,000 per invoice not issued in electronic format, applicable to both the issuer and the recipient who is not prepared to receive them. Furthermore:
- Failure to retain electronic invoices for the legally required 4 years: up to €6,000.
- Non-compliance with related fiscal or accounting requirements: up to €24,000.
- Breaching data security: up to €60,000.
The hidden cost of not adapting
Beyond fines, there is an operational cost that is already becoming apparent. Large companies and retail chains are requiring electronic invoicing as a condition for engaging suppliers. If your business cannot issue or receive structured-format invoices, you risk being excluded from major supply chains or facing payment delays due to format incompatibilities.
Practical guide: how to prepare step by step
Every business's situation is different. Here is a simplified outline to orient you based on your case:
Businesses invoicing the public sector
If you are not generating invoices in Facturae format and submitting them through FACe, you have an immediate problem. Check that your software generates the XML correctly and that your digital certificate is current.
Businesses and self-employed workers invoicing other professionals
- Check that your software will comply with Verifactu. Ask your vendor directly whether their product has already been adapted to RD 1007/2023. If the answer is vague or there is no active maintenance, it is time to switch.
- Get ahead of B2B e-invoicing. Although the deadline for most businesses is October 2028, the large companies you work with may move forward to October 2027. If your main clients are large accounts, the real timeline may be shorter than it appears.
- Talk to your value chain. The e-invoicing obligation is not one-sided: it affects both issuer and recipient. If your suppliers or clients are not ready, you will have problems too.
For billing software developers
If your product generates invoices and does not yet comply with Verifactu, the technical obligation has already passed (July 2025). Integrating an API like Verifacti's allows you to meet the integrity, chained hashing, QR code, and AEAT submission requirements in a matter of days, without having to build the direct integration with the Tax Agency — a process that typically takes three to six months.
Businesses that only invoice individual consumers
The Crea y Crece Law does not apply to you, but Verifactu probably does. If you use any kind of software to generate receipts or simplified invoices, that program must meet the technical requirements of RD 1007/2023 before July 2027.
Frequently asked questions
Is sending a PDF by email the same as issuing an electronic invoice?
No. A PDF is a digital invoice, but not a structured electronic invoice under the law. The regulation requires machine-readable formats such as UBL, Facturae, or XML. When the B2B obligation enters into force, continuing to send PDFs will constitute a sanctionable breach.
When does e-invoicing become mandatory in Spain?
It depends on the context. With public administrations, since 2015. Regarding software (Verifactu), from January 2027 for companies and July 2027 for the self-employed. For B2B transactions (Crea y Crece), expected from October 2027 for large companies and October 2028 for all others.
Does a bar or hair salon need to issue electronic invoices?
If they only invoice individual consumers, the Crea y Crece Law does not affect them. But if they use software or a POS system to generate receipts, that program must comply with Verifactu by the established deadlines.
Are SII-registered companies exempt from all of this?
They are excluded from Verifactu because they already report their records in real time to the AEAT. But the SII exclusion does not free them from the B2B e-invoicing obligation under the Crea y Crece Law. These are separate regulations with separate purposes.
Can I use the AEAT's public solution or do I need a private platform?
The Spanish system will be hybrid. You will be able to use the free public platform, an accredited private platform, or both simultaneously. The choice will depend on your invoice volume and your ERP integration needs.
What is the difference between Verifactu and mandatory e-invoicing?
Verifactu regulates the software that generates invoices (integrity, traceability, QR). Mandatory e-invoicing (Crea y Crece) regulates the format in which invoices are exchanged between businesses. The first affects the program; the second, the document and its delivery channel. Most companies will need to comply with both.