Regulatory status at the date of this update. Royal Decree 238/2026 has been in force since 20/04/2026, with deferred application. Order HAC/1028/2026, published in Spain’s Official State Gazette (BOE) on 05/10/2026, entered into force the following day. We will update this article if the Spanish Tax Agency (AEAT) publishes an official timetable with exact dates.
What happened on 06/10/2026
Law 18/2022 (the Crea y Crece Act on business creation and growth) introduced the obligation to issue and receive electronic invoices in transactions between businesses and professionals. Royal Decree 238/2026 implemented it, but made the start of the deadlines conditional on a ministerial order. Order HAC/1028/2026 regulates the public e-invoicing solution to be operated by the AEAT. Its sole final provision states that, upon its entry into force, the deadlines under Law 18/2022 and Royal Decree 238/2026 begin to run.
The order does not set calendar dates: it simply starts the clock.
Which group is your company in? The volume of transactions
The Fourth Final Provision of Royal Decree 238/2026 distinguishes two groups of businesses and professionals:
- Volume of transactions above €8,000,000 in the immediately preceding calendar year: application twelve months after the order enters into force.
- All other businesses and professionals: application twenty-four months after.
An important nuance: the threshold is measured by the volume of transactions calculated under art. 121 of the Spanish VAT Act (Law 37/1992), not by the net turnover shown in the annual accounts. The two figures do not always coincide, so you should not classify your company on the basis of the profit and loss account. Exactly which calendar year serves as the reference for each group is a question the AEAT ought to clarify; in the meantime, we recommend reviewing the 2025 volume and the 2026 forecast.
Indicative application dates
The dates in the table are our own calculations, counting the months from 06/10/2026. They are not dates published by the AEAT and must be confirmed before taking decisions. For reference, the Ministry of Finance, in its information note of 05/10/2026, places mandatory e-invoicing for those invoicing €8 million or less in October 2028, which is consistent with the 24-month count.
| Group | Criterion | Deadline (Royal Decree 238/2026) | Indicative date (inference) |
|---|---|---|---|
| Large invoicers | Volume of transactions (art. 121 VAT Act) above €8,000,000 | 12 months from the entry into force of the order | Around 06/10/2027 |
| All other businesses and professionals | Volume of transactions of €8,000,000 or less | 24 months | Around 06/10/2028 |
| Invoice statuses for individuals and income-attribution entities with €8,000,000 or less | Third Transitional Provision | 12 months after the obligation becomes applicable to them | Around 06/10/2029 |
| Subcontractors currently using FACeB2B | First Transitional Provision | Maximum of 24 months from the entry into force of the order | Around 06/10/2028 |
In addition, the Fifth Additional Provision requires the public solution to be available at least two months before the first effective application.
Invoice statuses and actual payment
The change with the greatest consequences is not the format but the information required after issue. Art. 10 of Royal Decree 238/2026 requires businesses to report the commercial acceptance or rejection of the invoice and its date, and the full actual payment with the actual payment date. Other statuses, such as partial payment or assignment to a third party, are voluntary. The reporting period is short: the royal decree sets it in days counted from when the status occurs, so reporting will have to be built into the collections and payments process rather than left to a manual month-end routine.
Invoices may be issued through private platforms or through the AEAT’s public solution, in one of the syntaxes accepted by art. 7 in accordance with European standard EN 16931: UBL, CII, EDIFACT or Facturae. The public solution uses UBL as its reference syntax. Simplified invoices are, as a general rule, outside the scope of the obligation (art. 4).
Transitional period with PDF
For the twelve months after the obligation applies to the group above €8,000,000, their e-invoices must be accompanied by a legible PDF representation, unless the recipient expressly agrees to receive them without it (Second Transitional Provision).
In the industrial supply chains of the province of Alicante, large buyers commonly sit alongside small workshops and suppliers. For several years, businesses that are subject to the obligation and businesses that are not will coexist, and each will need to know what to require from, and what to offer to, the other party.
What changes for accounting and audit
From the auditor’s point of view, e-invoices with statuses are a source of external, structured evidence. There are three practical effects:
- Sales and cut-off. The dates of issue, acceptance and rejection are recorded outside the company. Differences between what has been recorded in the accounts and what has been reported will be more visible, both to the auditor and to the tax authorities.
- Average payment period. Reporting actual payment will make compliance with the payment deadlines of Law 3/2004 on late payment, to which the royal decree itself refers, traceable. The notes to the annual accounts must already disclose the average supplier payment period in accordance with the Resolution of 29/01/2016 of the Spanish Institute of Accounting and Auditing (ICAC), the national audit oversight authority; the figure in the notes and the one produced by the system should be consistent.
- Internal control. Who accepts or rejects invoices, and when, becomes a decision with tax and reporting consequences. Responsibilities, authorisations and periodic reconciliations between the invoicing system and the accounting records need to be defined.
If your company needs to review these processes, the design of control systems and corporate strategy and support with the preparation of the annual accounts and the notes are good starting points. And if you operate in the province, you can see how we work as auditors in Alicante.
E-invoicing and VERI*FACTU: two different obligations
B2B e-invoicing should not be confused with the requirements for computerised invoicing systems under Royal Decree 1007/2023 (VERI*FACTU). They are different rules with different timetables, although the Ministry of Finance has announced its intention to align them. We explain this in the VERI*FACTU dates and the announced postponement.
Frequently asked questions
Is my volume of transactions measured using 2025 or 2026?
The royal decree refers to the volume of transactions of the «immediately preceding calendar year», without specifying in the text reviewed which date applies to each group. Until the AEAT clarifies this, the prudent approach is to review the 2025 volume and monitor the 2026 forecast, particularly if your company is close to €8,000,000.
Is sending the invoice as a PDF enough?
Not as a mandatory e-invoice. The PDF only accompanies the structured invoice during the transitional period for the group above €8,000,000, and the recipient may waive it.
What about the self-employed?
Self-employed individuals and income-attribution entities with €8,000,000 or less fall into the 24-month group. In addition, the obligation to report invoice statuses reaches them twelve months later and, until then, is voluntary.
Does it affect invoices to final consumers?
No. The obligation applies when the recipient is a business or professional with its registered office, permanent establishment or domicile in Spain. Simplified invoices are excluded as a general rule.
Official sources
- Royal Decree 238/2026 of 25 March (BOE no. 79, 31/03/2026)
- Order HAC/1028/2026 of 2 October regulating the public e-invoicing solution (BOE no. 247, 05/10/2026)
- Ministry of Finance, information note of 05/10/2026
- ICAC Resolution of 29/01/2016 on the average supplier payment period (BOE-A-2016-1112)
If you would like to review how e-invoicing affects your invoicing processes, your internal control or the disclosures in your notes, contact our team and we will analyse your case.
Article prepared by Controlaudit’s technical team. Updated on 08/10/2026. This content is for information only and is no substitute for professional advice on your specific case.