Electronic invoicing between businesses in Spain now has dates. If you invoice other businesses or professionals in Spain, you'll have to issue and receive your invoices in a structured electronic format. A PDF sent by email doesn't count.
The obligation comes from Law 18/2022, known as Crea y Crece, which added article 2 bis to Law 56/2007. The detail is in Royal Decree 238/2026 of 25 March. The clock started on 6 October 2026, when Order HAC/1028/2026, which regulates the public e-invoicing solution, came into force.
When it becomes mandatory
It depends on how much you invoice. The Spanish Tax Agency (AEAT) publishes this calendar:
| Date | Who | What starts |
|---|---|---|
| 6 October 2027 | Businesses and professionals with a turnover above 8 million euros | Issuing and receiving e-invoices, and reporting each invoice's status and payment |
| 6 October 2028 | All other businesses and professionals, freelancers included | Issuing and receiving e-invoices |
| 6 October 2028 | Companies and other entities up to 8 million | Also reporting invoice status and payments |
| 6 October 2029 | Freelancers and income-attribution entities | Reporting invoice status and payments |
Turnover means your VAT volume of operations in the previous calendar year.
If you're a freelancer (autónomo) or run a small company, your date is 6 October 2028. For freelancers, reporting statuses is voluntary until 6 October 2029.
Who it affects and what is left out
It covers invoices between businesses and professionals when the recipient is established in Spain. According to the AEAT, these are left out:
- Invoices to private individuals. If your client is a consumer, nothing changes.
- Simplified invoices, except qualified ones, which are those that identify the recipient.
- Transactions with businesses not established in Spain, intra-EU ones included.
- Transactions that don't require an invoice.
The rules don't change what an invoice must contain or when you have to issue it. That is still set by the invoicing regulation, which we go through in How to make a valid invoice in Spain.
What counts as an electronic invoice
For these purposes, an electronic invoice is a structured data message, meant to be read by software. The Royal Decree accepts four formats, all aligned with the European standard EN 16931:
- UBL
- CII
- EDIFACT
- Facturae
A PDF is none of them. Businesses above 8 million euros will have to attach a PDF to their e-invoices during their first twelve months, so that those not yet obliged can read them. The PDF goes with the electronic invoice. It doesn't replace it.
How invoices travel
The system has two parts:
- Private exchange platforms. They must interconnect when a customer asks, and send a copy of every invoice to the public solution.
- The public solution, run by the Tax Agency. It's free, it lets you issue and receive invoices, and it also acts as the repository for all of them.
You'll be able to use a private platform, the public solution, or both.
Invoice statuses
The rules exist to fight late payment. That's why sending the invoice isn't enough: you have to report what happens to it.
- Commercial acceptance or rejection, with its date. If there's no rejection, the invoice is taken as accepted.
- Full payment, with its date.
You have four calendar days to report, not counting Saturdays, Sundays or national holidays.
It isn't the same as Verifactu
The two are often confused, and they are separate obligations:
| Verifactu | E-invoicing | |
|---|---|---|
| What it regulates | How your software records each invoice | The format in which the invoice reaches your client |
| Which invoices | All of them, including those to individuals | Those you issue to businesses and freelancers in Spain |
| Rule | Royal Decree 1007/2023 | Royal Decree 238/2026 |
You may have to comply with both. Verifactu's dates are in What is Verifactu and when does it become mandatory.
What you can do now
- Check your date. Below 8 million euros a year, it's 6 October 2028.
- Sort your clients. Only invoices to businesses and freelancers in Spain are affected. Invoices to individuals and to clients abroad stay as they are.
- Keep your clients' details up to date. An e-invoice has to identify the recipient properly: tax ID, legal name and address.
- Record when you get paid. When it's your turn to report payments, you'll need the date.
How Factuly helps
Today Factuly produces your invoices as PDFs, with numbered series, your client's details saved and, if you invoice from Spain, the Verifactu record for each one. Every invoice has a status, and you mark it as paid with the day the money arrived, so the payment date is already on file. See Invoices and Verifactu in Factuly.
The dates in this article are those in force on 11 November 2026. If they change, you'll see it in the update date above.
