Is B2B e-invoicing already mandatory in Spain?

The legal obligation exists since Law 18/2022, but its effective application still depends on the completion of the regulatory framework and the Ministerial Order.

Which formats should invoicing software already support?

Based on what is currently known from the official draft, it makes sense to prepare for EN 16931 and syntaxes such as UBL, CII, EDIFACT, and Facturae.

Why does interoperability matter?

Because the Spanish model allows exchange between platforms and requires private solutions to transform messages between accepted formats. This directly affects ERP, POS, and invoicing software.

What role will invoice statuses play?

They will be key for tracking acceptance, rejection, and payment, and for improving traceability of payment terms. The draft even sets maximum deadlines for submitting that information.

B2B e-invoicing in Spain: guide for invoicing software & POS providers

Camille MendonçaFiscalization Expert Spain

3/17/20264 min read

B2B e-invoicing in Spain is getting closer to full rollout. According to Opinion No. 1203/2025 of the Council of State, published on January 29, 2026, the regulatory development of the Crea y Crece Law appears to have taken a meaningful step forward. In practical business and product terms, the message is clear: if you develop invoicing software, ERP, or POS systems, this is no longer about waiting. It is about preparing your architecture for a digital, structured, and interoperable model.

What does the Crea y Crece Law establish?

The Crea y Crece Law pursues two core goals: reducing late payments in commercial transactions and accelerating the digitalisation of the business landscape, especially for SMEs and self-employed professionals. To achieve this, the law extends the obligation to issue and send electronic invoices to all commercial relationships between businesses and professionals. The draft regulation highlights that this traceability will make it easier to track issue, delivery, acceptance, and payment dates, helping measure actual payment terms more accurately.

In addition, the system is designed as a hybrid model. On the one hand, private electronic invoice exchange platforms will be allowed to operate. On the other, the Spanish Tax Agency will have to develop and manage a voluntary public solution. When a company uses a private platform or solution to issue invoices, that solution will have to send a faithful electronic copy of each invoice to the public solution simultaneously in UBL syntax.

What should invoicing software vendors do?

Law 18/2022 already established the obligation to use e-invoicing between businesses and professionals, and what remained was to define the technical and operational framework. The official draft royal decree submitted for the second public consultation confirms exactly that step: it regulates the Spanish e-invoicing system, private exchange platforms, and the future public solution, while also adapting Royal Decree 1619/2012 on invoicing obligations to the new digital environment.

For you, this has a very practical consequence: your invoicing software, POS, or ERP system will no longer be able to stop at generating readable documents or PDFs sent by email. It will need to issue, receive, transform, and track structured invoices within an interoperable ecosystem, with lifecycle traceability and the ability to integrate with different channels and regulatory frameworks.

Technical requirements already known

As of today, the official draft provides a fairly clear picture of the expected technical requirements. The electronic invoice will need to be issued as a structured digital message aligned with the European semantic model EN 16931. Accepted syntaxes include CII, UBL, EDIFACT, and Facturae. The draft also clarifies that Peppol BIS messages are considered included when they use UBL syntax and comply with EN 16931.

Another key requirement already taking shape is interoperability. Private platforms will have to be able to transform invoice messages into the accepted formats, so that exchange is not blocked by the technology provider chosen by each company. For ERP, POS, and invoicing software providers, this makes interoperability a product requirement, not an optional enhancement.

Another important point is status management. At a minimum, the recipient will have to report commercial acceptance or rejection of the invoice and full effective payment with the corresponding date. Additional statuses may also be reported, such as partial acceptance or rejection, partial payment, or assignment of the invoice to a third party. As a general rule, this information will have to be submitted within a maximum period of 4 calendar days, excluding Saturdays, Sundays, and national public holidays.

Expected timeline and next steps

The timeline still depends on the approval of the Ministerial Order. According to the draft, the Royal Decree would take effect for companies with more than 8 million euros in turnover one year after that Order, and for all other businesses and professionals two years later.

In other words: even if the final timeline still depends on the completion of the legislative process, it makes sense to start evaluating solutions to adapt your software now. The more complex your stack is, the more valuable it is to start early with formats, integrations, validation flows, and status tracking.

Electronic invoicing in Europe

Spain is not moving alone. ViDA, the VAT in the Digital Age package, confirms the European direction toward more structured e-invoicing and more digital reporting. For intra-EU B2B transactions, the Digital Reporting Requirements will start on July 1, 2030, and Member States with domestic real-time reporting systems will have to align them with EU standards before January 1, 2035.

This shift is already visible across several markets. Germany has required companies to be able to receive EN 16931-compliant eInvoices since January 1, 2025, and will tighten structured issuance progressively between 2027 and 2028. Italy has operated a B2B and B2C mandate through the Sistema di Interscambio using the FatturaPA format since 2019. France will roll out its mandate in phases starting in September 2026, beginning with mandatory receipt for all companies and the expansion of e-reporting. Spain follows the same trend, although its final technical framework is still being completed.

How fiskaly can help

This is where fiskaly’s value proposition becomes especially relevant for developers and software providers. fiskaly is not positioned as a one-off solution for a single obligation, but as a provider of country-specific fiscalisation and compliance APIs, fully cloud-based and designed to integrate directly into third-party software. Our APIs support compliance with local rules in different markets such as KassenSichV in Germany, RKSV in Austria, and TicketBAI, Verifactu, SII, and B2B e-invoicing in Spain.

For B2B e-invoicing in Spain specifically, fiskaly offers an API integration designed for invoicing software, ERP, POS, and till systems, with support for formats recognised in Spain and across the EU such as UBL and Facturae, automatic updates, and a scalable architecture that avoids rebuilding your product every time regulation changes. This is especially useful for vendors with international ambitions: one integration can serve as the foundation for expansion into other European markets with different local requirements.

Put simply, if your challenge is to comply in Spain today without closing the door to Germany, Italy, France, or other countries, fiskaly gives you a more modular and scalable route than building every regulatory adaptation from scratch. That means less technical debt, less commercial friction, and a stronger foundation for growth across Europe.