- B2B electronic invoicing will be mandatory for all Spanish companies and self-employed individuals within 1 or 2 years from the Ministerial Order that activates the public invoicing solution.
- The Spanish Tax Agency (AEAT), through Verifactu and the public invoice repository, will monitor data integrity, payment deadlines and the fight against late payments.
- Companies must use structured formats (especially Facturae), approved software, and keep invoices digitally for at least 4 years.
- Failure to comply with mandatory electronic invoicing can result in high penalties, but anticipating the change allows you to gain efficiency and reduce administrative costs.
Mandatory electronic invoicing will completely change how businesses and freelancers invoice in Spain. If you own a business, are a freelancer, or work in an administrative department, you'll want to understand what the law requires, the actual deadlines, and what tools you'll need to avoid falling behind and risking penalties.
Although this topic has been discussed for years, the widespread implementation of B2B e-invoicing is still in the rollout phase and depends on key regulatory developments: the technical regulations for the Crea y Crece Law and the Ministerial Order that will govern the public invoicing solution. Meanwhile, there are already active obligations (especially with the government) and a fairly well-defined timeline that should be closely monitored.
What exactly is an electronic invoice and what makes it "mandatory"?
When we talk about an electronic invoice, we are not referring to a simple PDF attached to an email, but to a structured document in electronic format that is issued, sent, received and stored entirely digitally, complying with very specific technical and legal requirements.
This type of invoice is normally generated in XML-based formats (such as Facturae, UBL or CII) that allow accounting systems, ERPs and billing platforms to read and process it automatically, without typing data by hand or reviewing figures on paper.
A valid e-invoice must guarantee the authenticity of the issuer and the integrity of the content (usually through electronic signature or secure transmission channels), include all the mandatory fields of the Billing Regulation (Tax ID, taxable bases, VAT rates and fees, dates, description, payment terms, etc.) and be kept in its original format for the legal custody period.
We describe it as "mandatory" when a specific rule requires that, in certain operations (for example, between companies and professionals in Spain , or with the Public Administration), that invoice is always issued and received in electronic format and complying with a specific standard.
Legal framework: Crea y Crece Law, Anti-Fraud Law, Verifactu and the role of the AEAT
The obligation to use electronic invoicing in Spain rests on two major, complementary regulatory pillars: Law 18/2022, on the creation and growth of companies (the "Create and Grow" Law) , and Law 11/2021, known as the Anti-Fraud Law . Each addresses a different, but closely related, aspect.
On the one hand, the Create and Grow Law aims to promote entrepreneurship, reduce bureaucratic hurdles, and generalize electronic invoicing in B2B to improve transparency and combat late payments. Article 12 introduces the progressive obligation to use e-invoicing in transactions between businesses and professionals.
On the other hand, the Anti-Fraud Law focuses on combating tax fraud and regulates so-called Electronic Billing Systems (EBS), requiring that the software meet a series of requirements to prevent manipulation (deletion of invoices, double use, alteration of records, etc.). Within this framework, the Verifactu system was created , responsible for automatically sending billing records to the Tax Agency.
The State Tax Administration Agency (AEAT) will play a leading role: it must have a public electronic invoicing solution that acts as a central repository and source of information to control late payments, as well as mechanisms to receive reports of payment, delays or non-payments from companies and professionals.
When B2B invoices are exchanged entirely through private platforms, these platforms must automatically send a copy of each invoice to the public system . From there, the Spanish Tax Agency (AEAT) will extract payment and deadline statistics, which will feed into the State Observatory of Private Late Payments to monitor which sectors are complying with the rules more or less effectively.
Calendar: When will electronic invoicing between companies become mandatory?
The million-dollar question is when electronic invoicing between businesses and professionals will become mandatory. The answer depends on several regulatory milestones and has been delayed, but the general structure is clear: a phased implementation based on invoice volume.
The Create and Grow Law came into force on October 19, 2022, but suspended Article 12 (B2B electronic invoicing) until its regulatory development and the Ministerial Order regulating the technical details of the public solution and the accepted formats are approved.
This development is being implemented through a Royal Decree and a Ministerial Order from the Ministry of Finance . The draft Royal Decree was submitted for public comment in June 2023, and the Council of Ministers approved the text that develops the B2B electronic invoice on March 24/25, 2026, pending the Order that will activate the system.
Once the Ministerial Order regulating the AEAT's public invoicing solution is published, the final deadlines for companies and the self-employed will begin, which are as follows:
- Companies with a turnover exceeding €8.000.000They will have a term of 1 year since the publication of the Ministerial Order to adapt and begin issuing and receiving electronic invoices in their B2B relationships. In the date scenarios handled by the AEAT, that could place us around July 2027.
- Companies and self-employed individuals with a turnover of less than €8.000.000They will have a 2-year term from that same Order to adapt, which would foreseeably point to mid-2028.
From that moment on, in B2B operations within Spain the general rule will be electronic invoicing and digital storage for at least 4 years , accessible for tax inspections and checks at any time.
It is worth noting that 2026 is shaping up to be a critical transition year : although the full B2B obligation will not be effective until the deadlines start running, companies that get ahead will have more leeway to test systems, build teams and refine processes without feeling rushed.
Relationship with Verifactu and billing programs
B2B electronic invoicing and Verifactu are different pieces of the puzzle, although closely connected. While the former focuses on the format and exchange channel for invoices , Verifactu handles the automatic submission of invoicing records to the Spanish Tax Agency (AEAT) and the integrity of that data.
Since the implementation of Verifactu (July 2025), invoicing programs that want to be up-to-date must provide a series of functionalities: generate a complete and unalterable record for each invoice, send it to the AEAT optionally or automatically, and leave unequivocal proof that there is no manipulation.
The planned timetable in this area, after the one-year moratorium announced at the end of 2025, is approximately as follows: companies (legal entities) must use software compatible with Verifactu from January 1, 2027 , while the self-employed and other taxpayers will have until July 1, 2027.
For now, except for those already obligated through other means (for example, invoicing the Administration), it is not mandatory to send all invoices to the AEAT through Verifactu, but it will be mandatory to use approved or adapted programs that meet the technical requirements of the Anti-Fraud Law.
In practice, this means you'll need to review your current invoicing software and assess whether to upgrade to Verifactu and B2B e-invoicing, whether you need to integrate a specific API, or whether it's better to migrate to an ERP or cloud solution that's already prepared for both.
Mandatory requirements and exemptions: who has to issue electronic invoices
The ultimate goal is for the obligation to cover virtually all B2B transactions within Spanish territory , but the regulations provide for nuances depending on the type of transaction, the volume of business and the territorial scope.
Firstly, there is a group of taxpayers who have been required to do so for years: all companies and self-employed individuals who invoice Public Administrations have had to issue electronic invoices since January 2015, in accordance with Law 25/2013 and the Public Sector Contracts Law.
Furthermore, those acting as contractors and subcontractors for the Administration in contracts above certain amounts must also use electronic invoicing in their dealings with each other when payments are derived from those public contracts.
With the Crea y Crece Law, e-invoicing is extended to all business-to-business (B2B) transactions. It is anticipated that, once one or two years have passed since the Ministerial Order, all private Spanish businesses will be required to use electronic invoicing when the recipient is a business or professional established in Spain.
However, some possible exemptions or exclusions exist and are being debated , which will qualify the actual scope of the obligation. Among those appearing in drafts and preliminary communications, the following stand out:
- B2C OperationsThe obligation does not currently extend to transactions with end consumers. In other words, sales to private customers can still be documented with paper invoices or unstructured formats, unless another regulation requires it.
- Transactions with foreign clientsThose would be excluded in which one of the parties does not have its headquarters of economic activity, permanent establishment, or domicile or habitual residence for invoicing purposes in Spain.
- Certain self-employed individuals and very low-volume SMEsExemption scenarios are being considered for taxpayers who invoice less than €85.000 annually, those who pay taxes under the simplified tax regime, some agricultural sectors or certain wholesale trade, although these details will need to be confirmed in the final regulations.
- Low-value transactionsMany transactions under €400 or those where simplified invoices are already used could be excluded from the strict obligation of structured e-invoicing, as well as amounts under €3.000 in sectors such as hospitality, passenger transport or hairdressing, among others.
In any case, even when the issuance of electronic invoices is not mandatory in a given situation, nothing prevents the taxpayer from voluntarily choosing to always use e-invoices to standardize their processes , something that in the medium term can greatly simplify internal management.
Technical requirements, formats and paper of Facturae
To comply with regulations, it is not enough to simply "digitize" the invoice; it must be done in a format that meets the structuring and interoperability requirements established by law. In Spain, the reference standard is Facturae , the official format promoted by the Ministry of Economic Affairs.
Facturae is based on an XML file with a very strict structure (currently, the most widely used version is 3.2.2), where each piece of data goes in its corresponding tag: issuer and recipient information, detail lines, taxes, totals, payment methods, etc. Even a minor structural error can cause automatic rejection by the platforms that validate the invoice.
Along with Facturae, the regulations foresee accepting other standard structured formats widely used internationally, such as UBL (Universal Business Language) or CII, and even PDF with electronic signature in certain contexts, provided that its automatic reading and interoperability with other systems are guaranteed.
In sectors such as transport and logistics, the adoption of Facturae and structured formats is especially advanced, as they allow the integration of e-invoices with TMS, ERP, eCMR systems and delivery notes , reducing discrepancies in amounts and automating reconciliations.
Whatever the format, the software you use for invoicing must be able to issue, receive and store invoices in those standards , as well as exchange mandatory statuses (sent, accepted, rejected, paid, etc.), which is key to controlling payment deadlines and combating late payments.
Advantages for companies and the self-employed beyond complying with the law
Mandatory use may sound like an imposition, but the truth is that a well-implemented e-invoicing system offers very clear advantages in daily life , especially for those who handle a significant volume of documents.
In economic terms, migrating from paper to electronic format drastically reduces the costs of printing, shipping, physical archiving, and document destruction . Furthermore, it decreases human error by eliminating the need to transcribe data, resulting in fewer returns and less time wasted on corrections.
Furthermore, having all invoices centralized in an accessible digital repository greatly streamlines the process of finding information, responding to requests, and preparing accounting closings or tax returns. Connecting with accounting systems or tax forms is significantly simplified.
From a treasury perspective, the combination of e-invoicing with status reports and systems like Verifactu makes it much harder to conceal payment delays . This should foster a culture of more reasonable payment terms and reduce commercial delinquency, an explicit objective of the Crea y Crece Law.
Finally, the impact on sustainability and security is not insignificant: reducing the use of paper and physical transport of documents decreases the environmental footprint, while cloud storage and backups minimize the risk of data loss due to hardware failures or well-managed security incidents.
Criteria for choosing software and planning the digital transition
The key to achieving all of the above is the invoicing software. Choosing the right software—or thoroughly reviewing the one you already use—is crucial for a smooth transition. It's not just about complying with the law, but about gaining efficiency in your daily work.
In general, it makes sense to opt for an accounting or invoicing solution that is compatible with Facturae, ready for Verifactu, and that allows for the automation of as many processes as possible . Ideally, the system should integrate invoicing, accounting, collections, payments, inventory, and, if possible, payroll, to avoid information silos.
When evaluating tools, it's important to consider aspects such as interface usability (that it's intuitive and doesn't require a master's degree to issue an invoice), ease of learning for the team, and the adaptation curve. A very powerful but unusable program often ends up being underutilized.
It's also important that the software is scalable and integrates with other solutions you already use or may need (CRM, POS, e-commerce platforms, banking, etc.), preferably through APIs or standard connectors. This will make all the difference as your business grows.
Regarding infrastructure, many businesses are opting for cloud applications, which allow access from anywhere, remote work, and eliminating the need to maintain their own servers , perform manual version updates, or handle local backups.
Internal training and practical steps to adapt
However good the software is, if the people who use it daily don't master it, the change can become a source of frustration. That's why it's essential to plan basic, well-focused training for staff who issue, receive, or review invoices.
A good strategy typically combines short training sessions on basic software use with quick reference materials (internal guides, short videos, FAQs) and a period of more intensive support while the change is being implemented. The easier it is for people to ask questions and get their doubts resolved, the smoother the transition will be.
It's also not advisable to try to digitize everything at once. The most sensible approach is to design a schedule of gradual steps , starting, for example, with a small group of clients or suppliers who are easy to work with, or with specific types of documents, and expanding the scope as the system stabilizes.
The goal is to reach the mandatory deadlines with the processes already in place, without having to improvise at the last minute. This involves reviewing internal workflows (how invoices are approved, who validates them, how payments are reconciled) and adapting them to the new digital environment instead of simply replicating the paper-based process.
Finally, it will be essential to communicate the change to customers and suppliers , explain how they wish to receive or send invoices, and agree on formats and channels to avoid misunderstandings (for example, whether private platforms, certified email, customer portals, etc. will be used).
Specific obligations in transport and logistics
The transport and logistics sector is one of the most impacted by the reform, both due to the volume of transactions and the need to synchronize accounting and logistics data . Here, mandatory electronic invoicing is not only a tax issue, but also an operational one.
Transport companies must definitively abandon sending invoices in PDF or paper format and switch to interoperable structured formats (Facturae, UBL or CII) that integrate with TMS, ERPs and platforms of large international shippers or clients.
The invoice data must be consistent with the associated logistics documents (transport orders, eCMR, delivery notes). Any discrepancies in weights, packages, or dates may result in invoice rejections, payment delays, or even penalties if traceability patterns are detected.
Furthermore, the logic of states (invoice sent, accepted, rejected, paid) becomes especially relevant to avoid litigation and payment delays , as well as to comply with the maximum payment times that the law reinforces as a measure against late payments.
Although some specific technical obligations for transport still depend on final regulatory developments, it is clear that companies in the sector that anticipate the changes — by adjusting their TMS, ERPs and document exchange platforms — will have a significant advantage when e-invoicing becomes completely unavoidable.
Penalties and risks of not complying with mandatory electronic invoicing
Ignoring these changes is not an option. The regulations stipulate a range of fines and financial penalties for those who, being obligated to do so, fail to issue, manage, or properly store their electronic invoices, or who use dual-use or non-compliant software.
Among the sanctions considered in the regulatory projects and in the practice of the Administration are fines of up to €10.000 for infractions related to billing systems, which may be increased in case of recidivism or when a clear intention to defraud is proven.
Penalties are also considered, calculated as a percentage of the volume of transactions not properly invoiced , for example, 1% of the total amount not properly recorded, with minimums and maximums per quarter that can range from €300 to €6.000.
If the infringement affects the storage or preservation of invoices (for example, they are not kept for the required 4 years or it is not possible to retrieve them in their original format), the fines may be set at €300 per affected transaction or 2% of the amount of the invoices involved, whichever is higher.
Beyond the direct economic impact, the use of non-compliant software or the lack of traceability in invoices can lead to the loss of aid such as the Digital Kit , reputation problems with clients and suppliers, and even, in very serious cases of tax fraud, the temporary suspension of activity or the cancellation of the taxpayer's registration.
How can freelancers, SMEs and large companies prepare?
Adapting to electronic invoicing doesn't have to be traumatic if it's approached as a well-planned digitization project and not just a last-minute formality. Although the final technical details still depend on pending regulations, there are steps you can take now.
For the self-employed, the first step is usually to choose a simple but e-invoicing-compatible billing program , configure the digital certificate , familiarize themselves with the new invoice format, and ensure that all documentation is stored securely and in an organized manner.
In the case of SMEs and larger companies, a somewhat broader project may be necessary, including an audit of the current system, integration with accounting, banks and inventory , definition of new invoice approval workflows and training of various teams (administration, finance, sales, etc.).
In all cases, it is highly recommended to keep up to date with regulatory developments (by consulting official sources or relying on specialized advisors) and not hesitate to ask for professional help, especially if you handle large volumes of invoices or operate in several countries with different regulations.
The goal is that when the requirement is fully in place, the issuance, receipt, and archiving of electronic invoices will be a natural part of the daily operations of the business, without disruptions or interruptions in activity.
The widespread adoption of mandatory electronic invoicing may seem like a complex challenge, but if managed effectively, it becomes a real opportunity to modernize processes, cut costs, gain control over finances, and improve relationships with government agencies and business partners . Starting preparations early is the best way to turn this legal obligation into a clear competitive advantage.
