Spain E-Invoicing Requirements 2026: B2B and VERI*FACTU

Last reviewed: 16 September 2026

Spain e-invoicing requirements are moving toward a nationwide mandatory system for invoices exchanged between businesses and professionals. Royal Decree 238/2026 now establishes the main legal and operating framework, but the general B2B mandate has not yet reached its effective compliance dates.

The important point for businesses in September 2026 is that Spain’s B2B deadlines are linked to a separate Ministry of Finance order covering the technical operation of the public electronic-invoicing solution. Once that order enters into force, the main compliance periods will begin running.

This guide explains the current Spain e-invoicing rules, the upcoming B2B mandate, structured invoice formats, the public solution, private platforms, invoice-status reporting, B2G invoicing and the separate VERI*FACTU requirements.

Spain e-invoicing requirements at a glance

Is B2B electronic invoicing mandatory in Spain now?

Not yet for the nationwide private-sector B2B system.

Spain’s Law 18/2022 established the obligation for businesses and professionals to exchange electronic invoices. Royal Decree 238/2026, published on 31 March 2026 and in force from 20 April 2026, provides the detailed legal framework for how the system will operate.

However, the decree does not make every Spanish business start B2B e-invoicing immediately. Its effective application depends on the entry into force of a separate Ministry of Finance order that regulates technical aspects of the public electronic-invoicing solution.

Once that order enters into force, the timetable is:

• 12 months later: businesses and professionals whose annual turnover exceeded €8 million in the immediately preceding calendar year; and
• 24 months later: the remaining businesses and professionals covered by the mandate.

What is the current status of the technical order?

The Ministry of Finance published a draft order for the public electronic-invoicing solution in April 2026 as part of the public consultation and legislative development process.

The order is important because it is expected to specify technical matters such as:

• operation of the public e-invoicing solution;
• authentication and identification methods;
• UBL technical specifications;
• unique invoice coding;
• communication between private platforms and the public solution;
• payment-status messages; and
• other technical implementation requirements.

Businesses should monitor the Spanish Official State Gazette and the Spanish Tax Agency rather than calculating their final B2B compliance date from the date of Royal Decree 238/2026 itself.

Who will be covered by Spain’s B2B mandate?

The obligation generally applies to businesses and professionals that are required to issue invoices for their business or professional activities when the recipient is another business or professional connected to Spain under the rules.

A recipient can fall within the Spanish system where the relevant transaction is directed to:

• its headquarters of economic activity in Spain;
• a permanent establishment in Spain;
• its business domicile in Spain; or
• its habitual residence in Spain where the applicable rules use that test.

A Spanish VAT number alone may not always determine whether a particular cross-border transaction falls within the domestic mandate. International businesses should identify which establishment actually receives the supply.

The supplier remains responsible for meeting its invoicing obligations even when invoice preparation is outsourced to an accountant, service provider or customer under an authorised self-billing arrangement.

Transactions that may fall outside the general mandate

Royal Decree 238/2026 contains exclusions and special rules. Ordinary simplified invoices are generally outside the new B2B electronic-invoicing obligation, although certain qualifying simplified invoices containing additional customer and tax information can be treated differently.

The decree also contains limited sector-specific provisions. These should not be interpreted as broad exemptions for an entire industry without checking the exact legal conditions.

Which electronic invoice formats will Spain accept?

The new mandatory B2B system is based on structured, machine-readable electronic invoices rather than ordinary PDF documents.

The main structured syntaxes identified by Royal Decree 238/2026 include:

• CII — UN/CEFACT Cross Industry Invoice;
• UBL — Universal Business Language;
• EDIFACT — supported electronic invoice messages; and
• Facturae — Spain’s established structured electronic invoice format.

The formats are designed to support automatic processing and interoperability between systems.

Spain’s public electronic-invoicing solution will use UBL as its reference syntax. Private platforms will need to meet interoperability and technical requirements so invoices can move correctly across the Spanish system.

Will a PDF invoice be enough?

No, not when the mandatory B2B structured-invoicing rules apply.

A normal PDF can be easy for a person to read, but it does not contain the structured machine-readable invoice data required by Spain’s new B2B system.

Businesses should therefore distinguish between:

• a readable invoice document such as a PDF; and
• the structured electronic invoice required by the B2B mandate.

During a transitional period, some businesses may also need to provide a readable PDF representation alongside the structured invoice under the conditions established by the rules.

How Spain’s B2B e-invoicing system will work

Spain is creating a mixed electronic-invoicing model that combines a public solution with private electronic-invoice platforms.

The system will include:

1. A public electronic-invoicing solution developed and managed by the Spanish Tax Agency.
2. Private electronic-invoice exchange platforms that meet the applicable technical and interoperability requirements.
3. Interconnection between systems so businesses using different platforms can still exchange invoices.

A business may use the public solution, a suitable private platform or a combination of available routes depending on its needs and the final technical requirements.

Spain’s public electronic-invoicing solution

The Spanish Tax Agency is responsible for developing and managing the public electronic-invoicing solution.

The system is intended to provide an accessible electronic-invoicing route and also act as a central repository within the Spanish B2B framework.

Under Royal Decree 238/2026, businesses that use the public solution will use UBL according to the detailed requirements established by the technical ministerial order.

The public solution is expected to support functions including:

• electronic invoice issuance;
• invoice receipt;
• invoice retrieval;
• payment-status communication;
• interconnection with private platforms; and
• access for properly authorised representatives.

Will the public solution be free?

Royal Decree 238/2026 provides for free access to and use of the public electronic-invoicing solution.

This may be useful for freelancers and smaller businesses with relatively simple invoice processes. Businesses with high invoice volumes, ERP systems, automated workflows or international operations may still choose commercial platforms that provide additional functionality.

What happens if a business uses a private platform?

Spain’s system allows the use of compliant private electronic-invoice platforms.

Where an invoice is issued outside the public solution, the rules provide for a faithful electronic copy to be transmitted to the public solution in the required UBL format.

This allows the public infrastructure to maintain a central record while businesses continue using compatible commercial invoicing services.

Businesses using private platforms will also need to make their chosen electronic invoice entry point available as required by the rules.

Invoice acceptance and payment-status reporting

Spain’s B2B e-invoicing system is also intended to improve visibility into commercial payment periods.

Recipients will need to communicate specified invoice events, including information such as:

• commercial rejection where applicable;
• complete payment of an invoice;
• the effective payment date; and
• the payment due date.

Other invoice statuses may also be supported, including partial payments or other events specified by the system.

Businesses should make sure their future invoicing and accounting workflows can record invoice status information accurately rather than treating electronic invoicing as only a file-format change.

Spain B2G e-invoicing and FACe

Electronic invoicing to Spanish public administrations is separate from the upcoming private-sector B2B rollout.

B2G electronic invoicing has already been mandatory in many cases for years. Suppliers to Spanish public bodies commonly submit invoices through FACe or another applicable regional or local electronic entry point.

Public-sector electronic invoices normally use the Facturae format and can require administrative routing information such as DIR3 codes.

Before invoicing a Spanish public authority, a supplier should confirm:

• which electronic entry point must be used;
• the correct DIR3 codes;
• the required Facturae information;
• contract or purchase-order references;
• signature requirements where applicable; and
• any rules specific to the contracting authority.

B2B e-invoicing and VERI*FACTU are not the same

Spain’s B2B electronic-invoicing mandate and the VERI*FACTU invoicing-system rules are closely related to digital invoicing, but they regulate different things.

What is VERI*FACTU?

VERI*FACTU is commonly used to describe Spain’s rules for computerised invoicing systems. These rules are intended to make invoicing records secure, traceable and resistant to improper alteration or deletion.

Systems covered by the regulation must create invoice records according to the required technical standards.

Under the VERI*FACTU mode, billing records are transmitted to the Spanish Tax Agency. Covered software can also operate under the permitted non-VERI*FACTU framework where the applicable requirements are met.

The Spanish Tax Agency currently states that the main adaptation deadlines are:

• 1 January 2027: taxpayers subject to Corporate Income Tax; and
• 1 July 2027: other taxpayers covered by the regulation.

Businesses should therefore prepare for VERI*FACTU even though the nationwide B2B e-invoicing mandate follows a separate timetable.

Do SII businesses have to use VERI*FACTU?

Taxpayers covered by Spain’s Immediate Supply of VAT Information system, known as SII, are generally outside the RRSIF invoicing-software requirements for their own invoices under the relevant rules.

However, an exclusion from VERI*FACTU does not automatically mean that the business will be outside the separate mandatory B2B electronic-invoicing system.

The two compliance questions should be reviewed separately.

What about the Basque Country and Navarra?

Businesses operating in the Basque territories or Navarra should also check the applicable regional tax rules.

These territories have their own tax administrations and digital invoicing or reporting systems. For example, TicketBAI applies in parts of the Basque Country.

A business operating across several Spanish tax territories may therefore need to coordinate national B2B e-invoicing requirements with separate regional obligations.

Invoice issue deadlines in Spain

The move to structured electronic invoicing does not remove Spain’s ordinary rules about when invoices must be issued.

Where the recipient is acting as a business or professional, invoice timing is generally linked to the VAT and invoicing rules applicable to the transaction.

Different timing can apply to:

• intra-EU transactions;
• advance payments;
• summary invoices;
• rectifying invoices;
• continuous services; and
• other special transactions.

A technically valid electronic invoice can still be non-compliant if it is issued too late or contains incorrect tax information.

Storage and audit evidence

Businesses should preserve electronic invoices and supporting evidence in a way that protects authenticity, integrity, accessibility and readability for the applicable retention period.

Useful records can include:

• the original structured invoice;
• any readable invoice representation;
• platform transmission records;
• delivery confirmations;
• acceptance or rejection messages;
• payment-status information;
• rectifying invoices;
• electronic signatures or seals where used; and
• contracts and purchase-order evidence.

Tax, accounting and commercial retention periods can differ, so businesses should confirm the period that applies to their records.

How businesses can prepare now

1. Identify affected entities. List Spanish companies, permanent establishments and self-employed activities that may fall within the B2B mandate.
2. Check the €8 million threshold. Determine whether the earlier or later B2B phase is likely to apply.
3. Monitor the final ministerial order. The actual 12-month and 24-month countdown depends on its effective date.
4. Prepare for VERI*FACTU. Confirm the separate 2027 software deadline that applies to your business.
5. Map invoice types. Separate B2B, B2C, B2G, cross-border and simplified invoices.
6. Review invoicing software. Ask whether it will support structured formats and Spain’s public or private exchange infrastructure.
7. Review customer data. Check tax IDs, legal names, addresses and other master data.
8. Plan your exchange route. Consider whether the public solution, a private provider or an integrated approach is most appropriate.
9. Prepare payment-status workflows. Decide how payment and rejection information will be recorded and reported.
10. Test before your deadline. Do not wait until the final compliance date to test structured invoices with customers and suppliers.

Common mistakes to avoid

• Assuming B2B e-invoicing is already mandatory for every Spanish business. The effective B2B timetable still depends on the triggering technical order.
• Using 20 April 2026 as the B2B compliance date. That is the date Royal Decree 238/2026 entered into force, not the general B2B mandate date.
• Inventing fixed 2027 or 2028 B2B dates before the triggering order is final. Calculate the deadline only from the official effective date of the ministerial order.
• Confusing VERI*FACTU with B2B e-invoicing. They are separate compliance frameworks with different purposes and timelines.
• Assuming a PDF will meet the future B2B mandate. The mandatory system requires structured electronic invoice data.
• Ignoring payment-status requirements. Spain’s system includes more than simply sending the invoice file.
• Ignoring regional tax systems. Businesses in the Basque Country and Navarra may have additional requirements.

Frequently asked questions

Is B2B e-invoicing mandatory in Spain in September 2026?

The nationwide B2B mandate has not yet reached its general effective compliance dates. Royal Decree 238/2026 establishes the framework, but the 12-month and 24-month phase-in periods are linked to the entry into force of the technical ministerial order for the public solution.

When will companies with turnover above €8 million have to comply?

They will generally become subject to the B2B mandate 12 months after the triggering ministerial order enters into force.

When will smaller businesses and freelancers have to comply?

Other covered businesses and professionals generally enter the mandate 24 months after the triggering ministerial order enters into force.

Is a PDF considered a compliant B2B e-invoice?

An ordinary PDF will not satisfy the new mandatory structured B2B electronic-invoicing system. A compliant invoice must use one of the permitted structured electronic formats and follow the required exchange process.

Which electronic invoice formats are supported?

Royal Decree 238/2026 identifies CII, UBL, EDIFACT electronic invoice messages and Facturae among the supported syntaxes. UBL is used by the public solution.

Will Spain provide a free e-invoicing system?

Yes. Royal Decree 238/2026 provides for a public electronic-invoicing solution managed by the Spanish Tax Agency with free access and use.

Are autónomos included?

Self-employed professionals can fall within the B2B mandate when they meet the applicable conditions. Most would normally fall into the phase applying 24 months after the triggering ministerial order unless their turnover places them in the earlier phase.

Is FACe the new private-sector B2B platform?

No. FACe is primarily associated with electronic invoicing to Spanish public administrations. The new private-sector B2B framework includes a separate public solution managed by the Spanish Tax Agency.

When does VERI*FACTU become mandatory?

The current Spanish Tax Agency timetable requires covered Corporate Income Tax taxpayers to have compliant invoicing systems from 1 January 2027 and other covered taxpayers from 1 July 2027.

Is VERI*FACTU the same as mandatory B2B e-invoicing?

No. VERI*FACTU concerns invoicing software and invoice records, while the B2B mandate governs structured electronic invoice exchange between businesses and professionals.

Official Spanish e-invoicing resources

• BOE: Royal Decree 238/2026 on Mandatory B2B Electronic Invoicing
• BOE: Law 18/2022 on Business Creation and Growth
• Spanish Tax Agency: VERI*FACTU and Invoicing Systems
• Spanish Tax Agency: VERI*FACTU Frequently Asked Questions
• Spanish Tax Agency: Updated SIF Adaptation Deadlines
• FACe: Public-Sector Electronic Invoice Entry Point

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