What has been approved
Royal Decree 238/2026 of 25 March, implementing the system of mandatory electronic invoicing between businesses and professionals, published in Spain’s Official State Gazette (BOE) no. 79 of 31 March 2026 (BOE-A-2026-7295), completes the mandate in art. 12 of Law 18/2022 on the creation and growth of companies. Under its fourth final provision, it enters into force twenty days after publication, that is, on 20 April 2026.
However, the same provision defers effective application and counts it from the entry into force of a ministerial order issued by the Ministry of Finance.
The deadlines: everything depends on the ministerial order
| Who | Criterion | Effective application |
|---|---|---|
| Larger businesses and professionals | Volume of transactions (art. 121 of VAT Law 37/1992) above €8,000,000 in the immediately preceding calendar year | 12 months after the entry into force of the ministerial order |
| Other businesses and professionals | Volume of transactions of €8,000,000 or less | 24 months after the entry into force of the ministerial order |
| Individuals and pass-through entities with €8,000,000 or less | Reporting of invoice statuses (Transitional Provision 3) | Voluntary until 12 months after the obligation applies to them |
An important point: the threshold is measured by the volume of transactions for VAT purposes, not by the net turnover in the annual accounts. The two figures do not always coincide.
What changes
- Structured format. The invoice must be a message compliant with European standard EN 16931, in one of these syntaxes: UBL, CII, EDIFACT or Facturae (art. 7). A PDF is not an e-invoice for these purposes.
- Private platforms or public solution. Invoices may be exchanged through private platforms, which must convert between formats, or through the public solution to be operated by the Spanish Tax Agency (AEAT).
- Invoice statuses. Art. 10 requires the commercial acceptance or rejection and its date, and full effective payment and its date, to be reported within a short period of days from when they occur. Partial payments, partial acceptance or assignment to third parties are voluntary statuses.
- Exclusions. Simplified invoices are excluded as a general rule (art. 4), and it is envisaged that certain transactions may be excluded temporarily or permanently.
- Transition. For 12 months, invoices from the group above €8,000,000 must be accompanied by a readable PDF, unless the recipient expressly agrees to receive them without it (Transitional Provision 2). Subcontractors currently using FACeB2B have 24 months to adapt (Transitional Provision 1).
The implementing ministerial order
The piece that was still pending was the ministerial order provided for in the third final provision, which regulates, among other matters, the technical elements of the public solution, authentication and representation, the payment reporting service, the use of the UBL syntax, the unique coding of invoices and communication between the public solution and private platforms. It was published as Order HAC/1028/2026 (BOE of 5 October 2026) and entered into force on 6 October 2026, the date from which the 12- and 24-month periods run. The fifth additional provision also requires the public solution to be available at least two months before the first effective application.
What to do now
- Calculate your 2025 volume of transactions to know which group your company is likely to fall into.
- Ask your software provider about its plan for adapting to the formats and to the reporting of statuses.
- Review the acceptance, rejection and payment process for invoices received: it will now have reporting implications for the tax authorities.
- Reconcile invoicing and accounting, in particular the average supplier payment period disclosed in the notes to the annual accounts.
For the auditor, e-invoices with statuses will be external evidence on sales, cut-off and payments. To review these processes, you can rely on our corporate strategy and internal control team, on preparation of annual accounts or on the audit of annual accounts by our auditors in Alicante.
Frequently asked questions
From when do I have to issue e-invoices to other businesses?
The deadlines run from 6 October 2026, the date on which Order HAC/1028/2026 entered into force: 12 months if your volume of transactions exceeds €8,000,000 and 24 months for everyone else. We explain this in the deadlines for mandatory e-invoicing.
Does it affect invoices to final consumers?
No. The obligation concerns transactions between businesses and professionals. Simplified invoices are excluded as a general rule.
Is it the same as VERI*FACTU?
No. VERI*FACTU regulates computerised invoicing systems (Royal Decree 1007/2023) and has its own timetable, although both obligations will affect the same software.
Official sources
- Royal Decree 238/2026 of 25 March (BOE no. 79 of 31/03/2026, BOE-A-2026-7295)
- Law 18/2022 of 28 September on the creation and growth of companies (BOE)
- Spanish Tax Agency electronic office
If you want to prepare your company for e-invoicing and review its effect on internal control and on the annual accounts, contact our team.
Article prepared by Controlaudit’s technical team. Published on 31 March 2026. Reviewed on 8 October 2026. This content is for information purposes only and is not a substitute for professional advice on your specific case.