Spain Approves Mandatory B2B E-Invoicing: What the Royal Decree Means for Businesses

What did the Spanish government approve?

On 24 March 2026, the Council of Ministers approved a Royal Decree that makes B2B e-invoicing mandatory for all businesses and professionals operating in Spain. The decree implements the Crea y Crece Law (Law 18/2022), which was enacted in September 2022 but had been waiting for its implementing regulations.

The full title of the decree is "Real Decreto por el que se desarrolla el sistema de facturacion electronica obligatoria entre empresarios y profesionales y por el que se modifica el Reglamento por el que se regulan las obligaciones de facturacion."

The regulation targets one of Spain's most persistent business problems: late payments. Spanish companies currently wait an average of 80 days to be paid, well above the 60-day limit set by law. By digitising the invoicing process and tracking acceptance and payment dates, the government expects to give businesses better visibility over their cash flow and give regulators the data to enforce payment deadlines.

When do businesses need to comply?

The rollout is phased by company size, but the deadlines are not fixed calendar dates. Instead, they are tied to the publication of a Treasury ministerial order (orden ministerial de Hacienda) that will set the technical specifications for the system. The government expects this order before 1 July 2026.

Companies with annual turnover above EUR 8 million have 12 months from the publication of that ministerial order to comply. If the order is published by mid-2026, this group would need to be ready by roughly mid-2027.

All remaining businesses have 24 months from the same date, putting their deadline at roughly mid-2028.

The countdown only starts once the ministerial order is officially published in the Boletin Oficial del Estado (BOE). Until then, these are projected dates, not confirmed ones.

What counts as an electronic invoice?

The decree defines electronic invoices as structured files that can be read and processed automatically by software. PDF files, Excel spreadsheets, and scanned paper documents do not qualify. This is a meaningful distinction: many Spanish businesses currently exchange invoices as PDF attachments and may assume they are already compliant.

Invoices must also carry status information. Businesses will be required to report whether an invoice has been accepted and when it was actually paid. This payment-tracking requirement is directly linked to the late-payment problem the regulation aims to solve.

The accepted formats align with European standards: FacturaE (Spain's national format), UBL, and CII are all supported. For more detail on what these standards involve, see our EN 16931 explainer.

How will invoices be exchanged?

Businesses will have two options for exchanging electronic invoices. The first is a free public platform developed by the AEAT (Agencia Estatal de Administracion Tributaria), Spain's tax agency. This platform will use existing government identity verification systems and serve as both an exchange mechanism and a repository.

The second option is to use private e-invoicing platforms. However, these platforms must be interoperable with one another. The decree explicitly prevents vendor lock-in: no business should be forced to join a specific platform just because their customer or supplier uses it. Private platforms must interconnect so that invoices can flow freely between any two parties regardless of which service they use.

This is a different model from Spain's existing B2G system, where all invoices to the public sector flow through the centralised FACe platform. The B2B system gives businesses a choice between public and private infrastructure while requiring that private solutions remain open.

How does this relate to Verifactu?

Verifactu and B2B e-invoicing are separate regulations with different objectives, even though they are often discussed together. The government has been clear about the distinction.

B2B e-invoicing (this Royal Decree) focuses on how businesses exchange invoices with each other. The goal is to speed up payments, reduce administrative costs, and give both businesses and regulators visibility over payment timelines.

Verifactu focuses on the internal integrity of invoicing software. It requires certified software that creates a chained hash and electronic signature for each invoice, making it harder to alter or delete records after the fact. Verifactu entered into force recently but its practical obligations were postponed to 2027: January 2027 for corporate income tax payers, July 2027 for self-employed taxpayers.

Companies already reporting via the SII (Suministro Inmediato de Informacion) real-time reporting system are exempt from Verifactu, since they already provide invoice data to the AEAT in near-real time. For a fuller breakdown of both systems, see our Spain e-invoicing guide.

What are the penalties for non-compliance?

The penalties under the Crea y Crece Law are significant. Businesses that fail to issue or accept structured electronic invoices face fines of up to EUR 10,000 per infraction.

There are also penalties aimed at the software ecosystem. Businesses using invoicing software that does not meet the new requirements can be fined up to EUR 50,000 per year. Software vendors selling non-compliant invoicing systems risk penalties of up to EUR 150,000 per year per product.

These vendor-level penalties are designed to push the entire market towards compliance, not just individual businesses. If your e-invoicing provider has not started preparing for the new requirements, that should be a factor in your vendor evaluation.

What is the expected economic impact?

Spain already processes between 500 and 550 million electronic invoices annually, generating estimated savings of around EUR 2.7 billion for businesses. The government expects that once the B2B mandate is fully in effect and volumes increase, total savings could exceed EUR 8 billion.

The savings come from eliminating manual data entry, reducing errors, and accelerating payment cycles. Sectors such as automotive, consumer goods, and hospitality already use similar systems and have reported significant reductions in processing time and cost. The mandate extends these benefits across the entire economy.

How should businesses prepare?

The Hacienda ministerial order has not been published yet, so the compliance clock has not started. But that does not mean there is nothing to do. Businesses that wait for the final deadline will find themselves competing for provider capacity and technical resources alongside everyone else.

Start by auditing your current invoicing process. If you are exchanging invoices as PDF or Excel files, those will not qualify under the new rules. You need structured electronic formats. Check whether your accounting or ERP software can produce and receive invoices in FacturaE, UBL, or CII format.

Next, review your e-invoicing provider options. You will need either to connect to the AEAT public platform or use a private platform that meets the interoperability requirements. If you are already using a provider for B2G invoicing through FACe, ask whether they plan to support the B2B mandate as well.

Finally, consider the Verifactu requirements in parallel. If your invoicing software needs to be upgraded or replaced for Verifactu compliance (January or July 2027 depending on your tax status), it makes sense to address both requirements in a single project rather than doing two separate migrations. The e-Invoice Readiness Scorecard can help identify where your organisation stands across both requirements.