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E-invoicing in Spain

Upcoming Confidence: medium Checked 21 Jul 2026
ModelB2B · Crea y Crece (private platforms + free AEAT public solution) — separate from the VERI*FACTU billing-software regime
Required formatFacturae / UBL / CII (UN/CEFACT XML) / EDIFACT — EN 16931 semantics; UBL is the public solution's reference syntax
Timeline2027–28

Who is in scope

Domestic B2B only — issuer and recipient both empresarios/profesionales with seat, permanent establishment or residence in Spain. B2C excluded. Non-residents not in scope. Simplified invoices generally excluded unless they are 'qualified' simplified invoices. Invoice status/payment reporting is mandatory for all invoices. The AEAT public solution is free and voluntary; private exchange platforms must interoperate and convert between all four permitted syntaxes.

Key dates

  • 29 Sep 2022 Ley 18/2022 'Crea y Crece' creates the B2B e-invoicing obligation, subject to regulatory development.
  • 3 Dec 2025 Real Decreto-ley 15/2025 (BOE 3 Dec 2025) postpones VERI*FACTU by one year.
  • 31 Mar 2026 Real Decreto 238/2026 of 25 March published in BOE nº 79 — the long-awaited B2B e-invoicing regulation. In force 20 April 2026, but application deferred until the Hacienda ministerial order takes effect.
  • 16 Apr 2026 Draft ministerial order (proyecto de orden) on the AEAT public e-invoicing solution published for public consultation; expected entry into force 1 October 2026. NOT confirmed published in BOE as of 21 July 2026 — this date starts the whole clock.
  • 1 Jan 2027 VERI*FACTU (separate regime): invoicing software (SIF) must be adapted for taxpayers filing Corporate Income Tax.
  • ≈2027-10-01 (order + 12 months) B2B e-invoicing mandatory for businesses/professionals with prior-year turnover above €8 million.
  • 1 Jul 2027 VERI*FACTU: SIF adaptation deadline for all remaining obliged taxpayers (SMEs, self-employed).
  • ≈2028-10-01 (order + 24 months) B2B e-invoicing mandatory for all other businesses and self-employed professionals.
What practitioners get burned by

Spain is the single most-confused entry on any mandate table because there are TWO unrelated regimes running on different clocks: VERI*FACTU (a certified-billing-software / anti-fraud regime under RD 1007/2023, deadlines 1 Jan 2027 and 1 Jul 2027) and Crea y Crece B2B e-invoicing (RD 238/2026, deadlines pegged to a ministerial order). Vendors routinely merge them into one date; do not. Second, the Crea y Crece dates are still FLOATING — until the ministerial order is actually published in the BOE, '≈Oct 2027 / ≈Oct 2028' is a projection, which is why this entry is medium confidence rather than high. Third, both regimes have already slipped repeatedly, so present the dates as order-dependent rather than fixed.

Sources

4 of 6 are primary sources. Mandate dates move — treat this page as a starting point and confirm against the primary source before committing a plan.

Also in Europe

Planning for Spain?

A page is a starting point. A scoped analysis gives you the specification, the mapping and the effort — in weeks, not quarters.