E-invoicing in Spain: when is it mandatory and who must comply?

The question of when e-invoicing becomes mandatory in Spain has no single answer. It depends on who you are, how much you invoice, and who you invoice. And in 2026, with mandatory e-invoicing drawing closer for businesses and the self-employed, the confusion is understandable: two separate regulations coexist, their timelines overlap, and they affect different groups.

Before getting into deadlines and profiles, one distinction is worth clarifying upfront, as it prevents a lot of confusion: Verifactu and the Crea y Crece Law are not the same thing. Verifactu regulates billing software and its technical requirements for integrity and traceability. The Crea y Crece Law regulates the format in which invoices are exchanged between businesses. These are separate obligations, with separate timelines, and with different implications depending on who is affected.

Three types of obligation: not the same for everyone

Before diving into calendars and profiles, it helps to understand that Spain currently has three distinct situations that are often lumped together under "mandatory e-invoicing":

1. E-invoicing with public administrations (B2G). This obligation is already fully in force. Companies (SA, SL, UTE, and permanent establishments of non-residents) have been required to issue electronic invoices to public administrations since January 2015. Self-employed individuals contracting with the public sector have had the same obligation for contracts above 5,000 euros since that same date. There is nothing pending here: if you invoice public administrations and are not doing so electronically, you are already non-compliant.

2. Verifactu (certified billing software). This is not an obligation to issue invoices in electronic format: it is an obligation to use billing software that meets the technical requirements of Royal Decree 1007/2023, covering integrity, immutability, and record traceability. It affects the software that generates invoices, not the format of the document itself. Software manufacturers were required to have their products adapted by July 2025. For the businesses and self-employed professionals using them, the deadlines are set by RDL 15/2025.

3. B2B e-invoicing (Crea y Crece Law). This is the obligation to issue and receive invoices in a structured electronic format for transactions between businesses and professionals. On 16 April 2026, the Ministry of Finance published the draft Ministerial Order that will regulate the AEAT's public e-invoicing solution, the final regulatory step needed to activate the definitive deadlines.

Who is required to issue electronic invoices?

The B2B e-invoicing obligation, regulated by Law 18/2022 (Ley Crea y Crece), covers a broad range of parties, but there are also important exclusions worth knowing.

Those who are required:

• All companies, including public limited companies, private limited companies, cooperatives, associations, and foundations, in their transactions with other businesses or professionals (B2B).
• All self-employed individuals and independent professionals in their transactions with other businesses or professionals (B2B). 
• Any business or professional established in Spain that invoices a public administration (B2G). This obligation has been in force since 2015.

Excluded transactions:

• Transactions with individual consumers (B2C).  A shop selling to the general public, a café, a hairdresser: none of these are covered by the Crea y Crece Law. The regulation applies exclusively to transactions between businesses and professionals. 
• Simplified invoices (receipts). Also excluded, with the exception of "qualified simplified invoices" as defined in the implementing regulations.
• Transactions where either party does not have its registered office or a permanent establishment in Spain are likewise excluded. The regulation applies only where both issuer and recipient are established on Spanish territory.
• Sectoral exemptions for particularly vulnerable sectors may also be included in the final regulations, though these have not yet been confirmed.

Special case: SII-registered businesses

Large companies with annual turnover above 6 million euros are subject to the AEAT's Immediate Supply of Information (SII) system, which already establishes a structured VAT reporting framework. Under SII rules, companies covered by this system are excluded from the obligation to submit records to the AEAT under Verifactu, but they are not exempt from the future B2B e-invoicing obligation. These are coexisting obligations that serve different purposes.

When does e-invoicing become mandatory? A timeline by profile

The e-invoicing obligation in Spain does not arrive on a single date. The timeline varies depending on the profile of the party affected and the applicable regulation. Here is the current status of each segment.

What is already mandatory: software vendors

E-invoicing with public administrations (B2G). Has been in force since January 2015 for companies. If you invoice public administrations and are not doing so in Facturae format, you have been non-compliant for years.

Certified billing software (Verifactu). RDL 15/2025, published in the Official State Gazette on 3 December 2025, sets the following deadlines:

• Software developers & vendors: their products must have been adapted to the technical requirements of RD 1007/2023 since July 2025.
• Companies subject to corporate income tax: from 1 January 2027.
• Self-employed individuals and other affected parties: from 1 July 2027.

What is still pending: B2B e-invoicing

On 16 April 2026 the draft Ministerial Order that will develop the public B2B e-invoicing solution was published. This draft sets out the technical specifications for the public platform managed by the AEAT, the accreditation requirements for private platforms, the accepted formats, and the interoperability model between public and private solutions. According to the draft, the Ministerial Order would enter into force on 1 October 2026, a date that will be confirmed definitively upon publication in the Official State Gazette.

From that date, the mandatory deadlines would be as follows:

• Companies with annual turnover above 8 million euros: obligation to issue and receive B2B electronic invoices from 1 October 2027 (12 months after the Ministerial Order enters into force).
• All other businesses and professionals: deadline of 1 October 2028 (24 months after the Ministerial Order enters into force).

The draft also confirms that the Spanish B2B e-invoicing system will be hybrid: companies will be able to choose between accredited private platforms, the AEAT's free public solution, or a combination of both. The reference format for the public solution is UBL, though the draft also admits other structured formats such as Facturae. In addition, RD 238/2026 establishes the obligation to communicate invoice statuses, including the effective payment date and rejection where applicable, within a maximum of four calendar days, regardless of the platform used.

Even if the deadlines seem distant, the technical and organisational impact starts now, particularly for those who develop and maintain billing software. Building in adequate time for integration is the difference between a controlled adaptation and a race against the clock.

What happens if I fail to comply with the e-invoicing obligation?

The Crea y Crece Law establishes a penalty framework for non-compliance with the B2B e-invoicing obligation once it enters into force. The consequences fall into three categories:

Legal consequences*.* Penalties apply to both the issuer (who fails to issue in a compliant electronic format) and the recipient (who is not in a position to receive and process electronic invoices). Non-compliance by both parties is covered under the law's penalty framework.

Commercial consequences. Beyond direct penalties, non-compliance creates real operational friction: clients who cannot process paper invoices because their systems only accept structured formats, delays in the payment cycle, or exclusion from supply chains that already require e-invoicing as a contracting condition.

Software provider liability. Software manufacturers that market systems not adapted to the applicable technical requirements may also face liability. This is a relevant risk for ISVs, ERP providers, and developers distributing billing solutions. If you are looking to get your integration ready on time, evaluating a B2B e-invoicing API that lets you embed compliance may be the most straightforward option.

What do I need to comply with the e-invoicing obligation?

The answer depends on your profile. Here are the concrete steps for each situation.

If you invoice public administrations (B2G)

This obligation has been in force since 2015. If you are not complying, you are actively non-compliant. Verify that your software generates invoices in Facturae format and that you submit them through FACe (the General Electronic Invoice Entry Point for the State Administration) or the equivalent platform for the relevant administration.

If you invoice other businesses or professionals (B2B)

• Step 1: verify that your billing software is adapted to Verifactu. Software manufacturers were required to have this ready by July 2025. For companies subject to corporate income tax, the deadline is 1 January 2027; for self-employed individuals and other affected parties, it is 1 July 2027 (RDL 15/2025).
• Step 2: prepare for adaptation to B2B structured formats for e-invoicing. The draft Ministerial Order published on 16 April 2026 confirms UBL as the reference standard for the public solution and also admits Facturae. It is not yet urgent, but beginning the technical adaptation now, particularly around invoice status management and connection to the accredited public or private platform, avoids rework once the deadlines activate and the margin narrows.
• Step 3: inform clients and suppliers. The obligation affects both parties in the transaction. When it enters into force, both issuers and recipients must be ready. Getting ahead of that conversation with your value chain reduces surprises.

If you only invoice individual consumers (B2C)

The Crea y Crece Law does not apply to you: it regulates exclusively transactions between businesses and professionals. However, if you use a computerised billing system, you must verify that it meets the Verifactu technical requirements within the deadlines set by RDL 15/2025.

fiskaly and e-invoicing compliance in Spain

That is why at fiskaly we help you manage Verifactu technical compliance and prepare for the future B2B e-invoicing obligation from a single integration, without having to track every regulatory change on your own.

Here are the main advantages of working with our SIGN ES API:

• Experience in markets where B2B e-invoicing is already mandatory. We operate in more than ten European markets, including Italy and France, where the obligation is already in force. That gives us practical insight that a provider without international experience simply cannot offer.
• A single API for Verifactu, TicketBAI, SII, NaTicket, and B2B e-invoicing. Integrate the Verifactu technical requirements now and be positioned to absorb the B2B obligation when the regulation is published, without rewriting your integration.
• Automatic regulatory updates. When deadlines, formats, or technical specifications change, fiskaly manages those changes. Your system does not fall behind between one regulatory version and the next.
• Continuous monitoring of Spanish and European regulations. We track the evolution of the Crea y Crece Law framework, changes to Verifactu specifications, and the development of the ViDA package at the European level.
• Certified security. We operate with ISO 27001 (information security) and ISO 9001 (quality management) certifications.