Mandatory e-invoicing between businesses in Spain: what changes, when, and how to comply

What the Crea y Crece law actually requires

Law 18/2022 on business creation and growth does not regulate e-invoicing in an article of its own: its article 12 rewrites article 2 bis of Law 56/2007, and that is where the obligation lives. The text says that "all businesses and professionals must issue, send and receive electronic invoices in their commercial relations with other businesses and professionals", and adds a second obligation that almost nobody mentions: "the recipient and the issuer of electronic invoices must provide information on the status of the invoice".

Five rules follow from that:

• B2B scope. Transactions between businesses and professionals, whether companies or autónomos. Invoices to private individuals are outside it.
• Three verbs, not one. Issue, send and receive. Even if you issue few invoices, you will have to receive your suppliers' invoices electronically.
• Invoice status. Whoever receives an invoice reports whether they accept it and when they pay it. This is the heart of the measure: its stated purpose is to fight late payment, not to collect more VAT.
• Free interoperability. Platforms must interconnect at no charge, and a recipient cannot force a supplier onto a particular platform (paragraph 3 bis).
• Copies for four years. The recipient can request free copies of the invoices for four years.

What the law does not change matters just as much: not which VAT you charge, not when it accrues, not which returns you file. It changes the medium of the electronic invoice, the channel it travels through, and what happens after you send it. The mandatory content is still the one in the Invoicing Regulation explained in the guide to your first invoice.

E-invoicing is not Verifactu, even though everyone mixes them up

Both rules talk about invoices and arrive at almost the same time, but they regulate different things:

Verifactu is about verifiable invoices: the tax agency wants to check that no invoice has been deleted or altered, so it requires the software to generate an invoicing record chained to the previous one. You can comply by printing the invoice on paper with its QR code. E-invoicing is about electronic invoices: a structured, machine-readable file that travels through a platform to your client's system, and the client answers saying whether they accept it and when they pay it. Paper with a QR code does not qualify; a PDF by email does not either.

The two obligations stack. Royal Decree 238/2026 defines the mandatory electronic invoice as one produced by systems "adapted to article 29.2.j) of the General Tax Law", in other words by Verifactu software. And one nuance that misleads people: being in the SII takes you out of Verifactu, but not out of e-invoicing, because its regulation does not exclude those who keep their VAT books through the Immediate Supply of Information. If you are self-employed, your specific timeline is in Verifactu for autónomos.

The timeline: what the law says, what the regulation says, and what is still missing

This is where most of the invention has happened. Layer by layer, each with its source.

The law (2022). Published in the BOE on 29 September 2022. Its seventh final provision gave the Government six months to approve the regulation, and the eighth set the calendar in relative terms: article 12 "shall take effect, for businesses and professionals whose annual turnover exceeds eight million euros, one year after the regulatory development is approved" and "for the rest, two years after". No specific month or year.

The regulation (2026). It took three and a half years. It is Royal Decree 238/2026 of 25 March, published on 31 March 2026 and in force twenty days later. Its fourth final provision adds one more link: effective application is counted "from the entry into force of the ministerial order" of the Ministry of Finance that develops the public e-invoicing platform. Twelve months after it for anyone whose volume of operations (article 121 of the VAT Law) exceeded 8 million euros in the previous calendar year; twenty-four months for everyone else. The public platform must be available at least two months before the first date (fifth additional provision).

What is missing (September 2026). That order has not been published in the BOE as of this guide, so the clock has not started. The only honest arithmetic: if the order entered into force tomorrow, companies above 8 million would not be bound before September 2027, and everyone else, including almost every freelancer and small SL, not before September 2028. Every month of delay pushes both dates back.

• If you read "mandatory in 2025" or "from January 2026", that was a forecast based on a draft, not a date from the BOE.
• 2027 is the first year in which the obligation can start to apply, and only for large companies.
• What does have a fixed date in 2027 is Verifactu; the 2026-2027 tax calendar lists the firm dates.

One note that explains part of the delay: the law made article 12 conditional on an EU derogation from the VAT Directive; the regulation now cites Directive (EU) 2025/516, the VAT in the Digital Age reform of March 2025, as its framework.

Accepted formats and how the Spanish e-invoicing system works

Under article 7 of Royal Decree 238/2026, the electronic invoice is "a structured electronic message conforming to the EN16931 semantic data model" of the European standard, in one of four syntaxes:

• UBL, the international standard for business documents and the mandatory syntax of the public platform.
• CII, the United Nations cross-industry invoice.
• EDIFACT, the classic electronic data interchange format.
• Facturae, the Spanish format already used to invoice public administrations through FACe since Law 25/2013.

A PDF stops being an electronic invoice for these purposes, however well signed: article 9 of the Invoicing Regulation, as amended in 2026, requires it to be "issued, transmitted and received in electronic format" with those technical characteristics. A PDF is a picture; what is required is the structured data.

The system has two channels, which can be combined:

1. Private exchange platforms. Operators that meet article 13 (ISO/IEC 27001 certification, AS2 or AS4 protocols, advanced electronic signature, conversion between the four syntaxes) and that must interconnect free of charge with any other platform within one month at most. Every invoice they issue is electronically signed, and a faithful copy in UBL is sent at once to the public platform.
2. The public e-invoicing platform. Run by the AEAT, the Spanish tax agency, it is free, works in UBL and is the universal repository of all electronic invoices. It includes a free form to issue invoices and report statuses (first additional provision).

The default rule is simple: if you have not agreed with your suppliers to receive through a private platform, you are deemed to have chosen the public one. If you choose a private platform, you have to publish your entry point in your communications and on your website; if you do not, your entry point is the public platform. Every invoice will carry a unique code made up of the issuer's NIF, the number and series and the date, so the discipline of series and numbering also becomes an identification key. To operate you will use your digital certificate; the exact identification methods will be set by the ministerial order.

Invoice status and payment reporting: the genuinely new part

Invoice statuses are what will change your routine most, because they affect the invoices you receive. Article 10 obliges the recipient to inform the issuer of two things:

• The commercial acceptance or rejection of the invoice and its date.
• The full effective payment and its actual date.

Optionally, partial acceptances or rejections, partial payments and the assignment of the invoice to a third party. The deadline to report is four calendar days from each status, not counting Saturdays, Sundays or national public holidays.

Article 12 adds the key piece: reporting full payment, or rejection, to the public platform is always mandatory, even if issuer and recipient work through private platforms. It is done through a payment reporting service of the public platform itself, within four calendar days of payment, also stating the due date. If there is no rejection and no subsequent corrective invoice, the invoice is presumed accepted. The issuer may voluntarily report collection or non-payment and dispute the client's dates.

The reason: the law wants to measure and publish who pays late. The payment period is calculated under Law 3/2004 on late payment, and the AEAT will pass the information to the Ministries of Economy and Industry and, each first quarter, to the State Observatory on Private Late Payment for the list of non-compliant companies.

Two transitional periods soften the start. Companies above 8 million will attach a readable PDF to their invoices during the first twelve months, unless the client agrees to receive only the original format. And individuals with a volume of operations of up to 8 million (freelancers, in practice) will not be obliged to report statuses until twelve months after their application date. For this to be manageable, your bookkeeping and payment reconciliation need to be up to date: you cannot report within four days a payment you do not know you have made.

What an SL has to do

For a sociedad limitada the order of priorities is clear, because one of the two obligations already has a date:

1. Verifactu first. From 1 January 2027 your SL invoices with software that generates chained records and QR codes. It is the nearest firm date and the one that decides which software you use.
2. Find your place in the calendar. Work out your previous year's volume of operations under article 121 of the VAT Law. Above 8 million: first group, twelve months after the order. Below: second group, twenty-four months. Almost every small SL is in the second.
3. Choose your channel. Public platform (free, in UBL) or a private platform. If you agree nothing with your suppliers, the default is the public one. If you contract a private one, check that it meets article 13.
4. Publish your entry point if you use a private platform, in your communications and on your website.
5. Organise reception. Every invoice received will have to be accepted or rejected and, once paid, reported to the public platform within four calendar days. The person who pays and the person who does the books have to work on the same system.
6. Keep the company's digital certificate current: it is your key to the public platform.
7. Retention. Your clients can ask you for free copies of your electronic invoices for four years.

None of this alters your tax obligations: you still file the modelo 303 with the same figures, and the full map for your company is still the guide to the tax duties of a Spanish SL. What changes is that the data of every invoice, and of its payment, will also sit in a public repository.

What a freelancer (autónomo) has to do

If you are an autónomo you have more room, but also more noise around you. Five things to be clear about:

• Your first date is Verifactu, 1 July 2027. From that day, any invoice you issue with software comes out of an adapted system; Verifactu for autónomos covers it.
• B2B e-invoicing reaches you in the second group, twenty-four months after the ministerial order, and during your first twelve months status reporting is voluntary.
• It only affects your invoices to businesses and professionals established in Spain. Invoices to consumers are outside it; so are simplified invoices, except the qualified ones under article 7.2 of the Invoicing Regulation; and invoices to foreign clients with no establishment in Spain do not enter the system, because article 3 requires the recipient to have its seat, establishment or domicile here. How to invoice those clients is in the guide to invoicing foreign clients without VAT.
• Receiving affects you too. Invoices from your gestoría, your software or your coworking space will arrive as electronic invoices and, once the transitional period is over, you will have to accept them and report their payment within four days. It is the discipline the guide to deductible expenses already asks of you: every expense with its invoice, every invoice with its payment.
• There is a free option. The AEAT's form to issue invoices and report statuses. Like the free Verifactu app, it complies, but it only invoices: no bookkeeping, no returns. The comparison is in Verifactu versus the AEAT's free app.

The useful preparation today is that of any well-made invoice: sequential series without gaps, verified client NIFs, and issuing every invoice from a single program. What the guide to your first invoice says still applies: the mandatory content does not change, the wrapper does.

Penalties: three separate regimes that should not be confused

Figures from three different laws get mixed up. All three are in the BOE; none is an estimate.

1. The Crea y Crece penalty. Article 2 bis.9 of Law 56/2007 provides for "a warning or a fine of up to 10,000 euros" for companies which, being obliged to, "do not offer users the possibility of receiving electronic invoices or do not allow persons who have ceased to be clients to access their invoices". It is imposed by the Secretary of State for Digitalisation and Artificial Intelligence. It is administrative, not a tax penalty, and Royal Decree 238/2026 adds none of its own.
2. The invoicing infringements in the General Tax Law. Article 201 of the LGT punishes failing to meet invoicing requirements with 1% of the amount of the transactions concerned; failing to issue or keep invoices with 2%, or 300 euros per transaction where the amount is unknown; and issuing invoices with false data with 75%. All double if the breach is substantial. It is the tax penalty the AEAT can apply if an invoice does not meet the Invoicing Regulation.
3. The Verifactu fine. Article 201 bis of the LGT sets 50,000 euros per tax year for anyone invoicing with a non-compliant system and 150,000 for anyone manufacturing or selling one. It is flat, not proportional, and it is the only one of the three with an application date: 2027.

In practice, the nearest and highest risk is not e-invoicing but continuing to invoice in 2027 with a tool that is not adapted to Verifactu; the guide to what Verifactu is covers it. E-invoicing will come later, and when the ministerial order sets the calendar this guide will be updated with the exact dates.

Where kontora fits, and what you can get ready today

It is worth being precise about what exists and what does not. Today kontora issues complete invoices with sequential series, generates invoices in Facturae format and files them with FACe for public-sector clients, and is built on hash-chained records with QR codes, which is what Verifactu requires. Facturae is also one of the four syntaxes the B2B system accepts.

What does not yet exist, for anyone, is the AEAT's public platform or the ministerial order that will define how it is accessed and how payments are reported. Any vendor who assures you today that it is "certified" for B2B e-invoicing is selling you something the AEAT has not yet published. The honest position is that the obligation has a regulation, has no date, and that the final adaptation will depend on that order.

What you can get done now, which serves both Verifactu and whatever comes next:

• A single series per year, with no gaps or repeats, and a separate series for corrective invoices.
• Your business clients' NIFs verified: the NIF, NIE and IBAN validator checks format and check digit in seconds.
• Your VAT record books up to date, because the 303 and, in due course, the public repository data will come out of them.
• Receipts and payments reconciled with the bank every week, so you can report a payment within four days without hunting for it.

kontora does the first, third and fourth by design: the accounts are generated from your invoices and expenses, and the drafts of your returns come out box by box for you to file yourself at the AEAT. When the order publishes the specifications, we will tell you what changes in the app and what you will need to do, without promising anything in advance.

Frequently asked questions

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