Mandatory e-invoicing between businesses in Spain: who, when, and what a PDF no longer covers

Most businesses in Spain still invoice each other with a PDF by email. That's coming to an end. Under the Ley Crea y Crece, every invoice between businesses and professionals will have to be a structured electronic invoice: a file that software can read, not a document a person reads.

Unlike Verifactu, these dates aren't up for discussion. They're in the BOE. This article covers what the rules ask, when they apply to you, and what to do now.

This isn't legal or tax advice, and we're not gestores. It's the practical orientation we give clients, with the official source for every point. For your own situation, ask your gestor.

What is mandatory e-invoicing?

The obligation comes from Ley 18/2022 ("Crea y Crece") and is developed by Real Decreto 238/2026, published in the BOE on 31 March 2026. The aim of the law is to fight late payment: if every invoice and every payment passes through a system, it's visible who pays late.

In practice it means three things:

1. You send invoices to other businesses as a structured file, not as a PDF.
2. Your customer reports whether they accept or reject the invoice, and when they paid it.
3. All of it goes through, or is copied to, a public solution of the Agencia Tributaria.

Who does it apply to?

The obligation covers invoices from businesses and professionals to other businesses and professionals with their seat, permanent establishment or domicile in Spain (article 3.1). So: B2B. Autónomos included.

Not included:

• Invoices to consumers (B2C).
• Simplified invoices (tickets), unless they are facturas simplificadas cualificadas (article 4.1).
• A few specific sectors, such as regulated electricity and gas market operators.

When? The dates are fixed

The deadlines in Real Decreto 238/2026 run from the entry into force of the ministerial order that regulates the public solution. That order, Orden HAC/1028/2026, was published on 5 October 2026 and came into force on 6 October 2026. So:

• Turnover above 8 million euros in the previous year: from 6 October 2027.
• Everyone else, including autónomos and most SMEs: from 6 October 2028.

Two transitional rules make it a little easier:

• Large businesses have to send a readable PDF along with the e-invoice during their first twelve months, unless the customer accepts the electronic format alone.
• For autónomos and other natural persons with turnover up to 8 million euros, reporting the status of invoices (accepted, rejected, paid) is voluntary for twelve more months after their own date. By our count that means October 2029.

What counts as an e-invoice?

Not a PDF, and not a scanned paper invoice. Article 7.1 requires a structured message that follows the European semantic model EN 16931, in one of four formats:

• UBL
• CII
• EDIFACT
• Facturae, the Spanish format already used for invoices to the public sector

You don't have to build these files yourself. Your invoicing software makes them. The question is whether your software can.

Public solution or private platform

There are two routes, and you can combine them:

• The public solution of the Agencia Tributaria. It's free to use (article 11.10) and acts as a repository of invoices. If your customer hasn't agreed to receive invoices through a private platform, the public solution is the default (article 6.1).
• A private platform, such as the e-invoicing service built into your invoicing software. Invoices issued through a private platform need an advanced electronic signature, and the platform has to send a copy in UBL to the public solution at the same moment (articles 6.2 and 7.3).

The law requires the public solution to be available at least two months before the first date.

The four-day rule

This is the part that changes daily work the most. Whoever receives an invoice has to report:

• whether they accept or reject it, with the date;
• when they've paid it in full, with the actual payment date.

The deadline is four calendar days, not counting Saturdays, Sundays and national holidays (articles 10.3 and 12.3). If no rejection comes in, the invoice is assumed to be accepted. So it's not just about sending: your bookkeeping has to keep up with incoming invoices and payments too.

What to do now

You have a year (large businesses) or two (everyone else). That sounds like plenty, but changing invoicing software, cleaning up customer data and teaching your team new habits takes time. And if the announced Verifactu postponement goes ahead, both changes land in the same month: October 2028. It's sensible to tackle them together.

We implement Holded as an official Solution Partner, so we're not neutral on software. Whatever program you use, ask your provider two questions: when will it send and receive e-invoices in one of the four formats, and how does it handle incoming invoice statuses?

Want to move your invoicing to software that's ready for e-invoicing and Verifactu at once? Book the call and we'll look at what you use now and what moving would involve.

Sources

• Real Decreto 238/2026, de 25 de marzo, B2B e-invoicing (BOE)
• Orden HAC/1028/2026, de 2 de octubre, public e-invoicing solution (BOE-A-2026-20587)
• Ley 18/2022, de 28 de septiembre, de creación y crecimiento de empresas (BOE)
• Ministerio de Hacienda: nota informativa on Verifactu of 5 October 2026 (PDF)

Noah WinkelmanSelva Digital

Builds websites and the systems behind them for small businesses in Spain and the Netherlands. Writes down the things clients ask twice.