The introduction of electronic invoicing in Spain represents a significant change to the country's business and legal framework. With the publication of Order HAC/1028/2026 of 2 October 2026, the specific implementation dates have now been established.

From 6 October 2027, electronic invoicing will initially become mandatory for companies and self-employed professionals whose annual volume of transactions exceeds EUR 8 million. From 6 October 2028, the obligation will generally extend to all other businesses and professionals falling within the scope of the legislation.

Objectives of electronic invoicing

Through Law 18/2022 of 28 September 2022, known as the Ley Crea y Crece, Spain primarily seeks to achieve the following objectives:

• Combat late payments in commercial transactions between businesses.
• Promote the digitalisation of business transactions.
• Simplify administrative procedures.
• Reduce administrative costs.
• Improve transparency in the issuance and payment of invoices.

Electronic invoicing will progressively replace the customary exchange of PDF invoices between businesses.

In addition, new reporting obligations will be introduced to enable more effective monitoring of invoice processing and payment.

What is an electronic invoice?

Many businesses already send their invoices by email in PDF format.

However, a PDF invoice generally does not meet the new legal requirements for mandatory electronic invoicing between businesses.

In future, invoices must be issued in a structured electronic format that allows automated processing by computer systems.

Specific technical standards will apply, particularly European standard EN 16931 and the UBL format prescribed for the public electronic invoicing platform.

A special transitional arrangement applies to larger businesses during the first twelve months of their mandatory compliance period. As a general rule, electronic invoices must also be accompanied by a readable PDF document, unless the recipient expressly and voluntarily agrees to receive them in their original structured format.

Current legal framework (October 2026)

Royal Decree 238/2026 of 25 March 2026 establishes the principal legal requirements for mandatory electronic invoicing.

The subsequent Order HAC/1028/2026 of 2 October 2026 was published in Spain's Official State Gazette (BOE) on 5 October 2026 and entered into force on 6 October 2026.

Its entry into force triggered the statutory transitional periods.

Implementation deadlines for mandatory electronic invoicing

The EUR 8 million threshold is determined by reference to the volume of transactions (volumen de operaciones) in the preceding calendar year, in accordance with Article 121 of Spanish VAT Law 37/1992.

Important for self-employed professionals: The extended deadline until October 2029 applies to certain additional reporting obligations. The obligation to issue electronic invoices generally applies to the self-employed professionals concerned from 6 October 2028.

Who is required to issue electronic invoices?

The new legislation generally applies to transactions between businesses and self-employed professionals (B2B).

Those affected include Spanish companies such as S.L. and S.A. entities, sole traders and self-employed professionals (autónomos).

Invoices issued to private consumers (B2C) are generally not subject to this mandatory B2B electronic invoicing requirement.

Certain statutory exemptions also apply, including exemptions for specific types of simplified invoices (facturas simplificadas).

For cross-border business transactions, it is necessary to determine whether the invoice recipient is established in Spain or whether the transaction is attributable to a permanent establishment located in Spain.

Consequently, not every invoice issued by a Spanish business to a foreign customer automatically falls within the scope of the new requirement.

Public invoicing platform and new reporting obligations

A key element of the reform is the introduction of a free public electronic invoicing platform.

This platform, known as the Solución Pública de Facturación Electrónica (SPFE), will be provided by the Spanish Tax Agency (Agencia Estatal de Administración Tributaria – AEAT).

Businesses may alternatively use private invoicing software and electronic invoicing platforms, provided that they comply with the applicable legal requirements.

Where a private platform is used, an electronic copy of the invoice must generally also be submitted to the public platform in the prescribed UBL format.

In addition, new invoice and payment status reporting obligations will be introduced.

Invoice recipients subject to these requirements must electronically report, among other information, the commercial acceptance or rejection of an invoice and its payment in full, including the relevant dates.

As a general rule, these notifications must be submitted within a maximum of four days following the relevant event, excluding Saturdays, Sundays and national public holidays. Specific provisions apply to notifications submitted through the public platform.

Businesses will therefore need to adapt not only their invoice issuance and receipt procedures, but also their payment monitoring and control processes.

Veri*Factu and electronic invoicing: two different systems

In practice, the two reforms are frequently confused.

However, they concern two distinct legal obligations.

1. Veri*Factu

The legislation associated with Veri*Factu is primarily based on:

• Law 11/2021 on measures to prevent and combat tax fraud.
• Royal Decree 1007/2023.

This legislation does not primarily regulate the exchange of electronic invoices between businesses. Instead, it establishes technical requirements for the invoicing software used by businesses and professionals.

In particular, these systems must:

• Provide protection against unauthorised manipulation.
• Ensure the traceability of transactions and modifications.
• Generate invoicing records that meet the statutory requirements for integrity and immutability.
• Allow invoicing records to be transmitted to the Spanish Tax Agency, depending on the system configuration used.

2. Electronic invoicing

Mandatory electronic invoicing, on the other hand, is governed primarily by:

• Law 18/2022 (Ley Crea y Crece).
• Royal Decree 238/2026.
• Order HAC/1028/2026.

This legislation focuses on the electronic exchange of structured invoices between businesses and self-employed professionals.

It also introduces certain obligations to report invoice and payment status information electronically.

Important: Compliance with the requirements applicable to invoicing software does not automatically satisfy the mandatory electronic invoicing requirements, and vice versa.

Veri*Factu implementation deadlines

The following deadlines have been established for adapting invoicing software to the statutory requirements:

Companies

Mandatory compliance for the relevant taxpayers from 1 January 2027.

Other businesses and self-employed professionals

Mandatory compliance for the relevant taxpayers from 1 July 2027.

These deadlines were extended at the end of 2025 by Royal Decree-Law 15/2025.

Existing electronic invoicing obligations

Independently of the new general obligation, electronic invoicing is already mandatory in certain circumstances in Spain.

This applies particularly to invoices issued to public administrations and certain public-sector bodies.

Specific electronic procedures are already in place for these transactions, particularly through the FACe platform.

The new B2B electronic invoicing rules supplement these existing obligations.

What should businesses and self-employed professionals do now?

Although the general electronic invoicing obligation will not take effect until October 2027 or October 2028, businesses and professionals concerned should prepare for the new requirements well in advance.

In particular, it is advisable to check whether existing invoicing and accounting software will comply with the new legal requirements.

Internal procedures for issuing and receiving invoices, as well as monitoring payments, should also be adapted accordingly.

Businesses engaged in international transactions should additionally determine which invoices actually fall within the scope of Spain's mandatory electronic invoicing rules.

Developments at European Union level

The digitalisation of Value Added Tax (VAT) is also progressing at European level.

Through the VAT in the Digital Age (ViDA) reform package, the European Union envisages the gradual expansion of electronic invoicing and digital reporting obligations for cross-border transactions.

Conclusion

Mandatory electronic invoicing represents an important step towards the digitalisation of business activity in Spain.

With the publication of Order HAC/1028/2026, the specific implementation dates have now been established.

For larger businesses, mandatory B2B electronic invoicing will begin on 6 October 2027, while the obligation will generally apply to other businesses and self-employed professionals from 6 October 2028.

Additional obligations to report invoice and payment status information will also be introduced progressively.

Separately, many businesses will be required to comply with the new invoicing software requirements from January or July 2027.

Companies and self-employed professionals should therefore use the remaining time to prepare their invoicing software and internal procedures for both reforms.

As lawyers, tax advisers and an accredited Entrepreneur Support Point (PAE), our law firm can assist you in assessing your individual circumstances, completing the relevant administrative procedures and filing the necessary tax returns. Further information about our services for businesses and self-employed professionals can be found in our Business section.

If you would like further information or have specific questions about this subject, please do not hesitate to contact us by email or telephone.

Disclaimer: The information provided in this article reflects the legal position as at 29 October 2026 and is intended for general information purposes only. The specific obligations applicable in each case depend on the individual business and tax circumstances.

Author:

Lisa Wörfel
Tax Advisor
info@sspartners.es
Tel: (+34) 951 12 13 06
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