The introduction of electronic invoicing in Spain represents a significant change in the country's economic and legal framework. But what exactly does this reform involve, and which deadlines do companies and self-employed professionals need to be aware of?

Objectives of Electronic Invoicing

With Law 18/2022 (“Ley Crea y Crece”), Spain is pursuing several economic and tax policy objectives.

These include in particular:

• combating late payments between businesses
• digitalising business transactions
• simplifying administrative processes
• reducing administrative costs, particularly for SMEs
• promoting electronic means of payment
• improving transparency in business transactions
• simplifying tax controls

In the future, electronic invoices are intended to largely replace the current exchange of conventional PDF invoices between businesses.

What Is an Electronic Invoice?

Many businesses already send invoices as PDF files by email.

However, a PDF invoice generally does not meet the requirements of the new legislation.

In the future, invoices will have to be issued in a structured electronic format that can be processed electronically. This will allow invoices to be received, processed and archived automatically.

Current Legal Situation (as of July 2026)

With Royal Decree 238/2026 of 25 March 2026, the long-awaited implementing regulation on electronic invoicing was adopted.

The main legal framework for the introduction of mandatory B2B electronic invoicing has therefore now been established.

However, practical implementation will not take place immediately.

The Ministry of Economy must first issue a ministerial order regulating, in particular, the technical requirements for the public electronic invoicing platform.

The statutory transitional periods will only begin once this ministerial order enters into force.

Deadlines for Mandatory E-Invoicing

Under the current legal framework, the following transitional periods apply:

Companies with annual turnover exceeding €8 million

These companies will be required to use electronic invoicing 12 months after the ministerial order enters into force.

Companies with annual turnover of up to €8 million and self-employed professionals

For these businesses and professionals, a transitional period of 24 months after the ministerial order enters into force applies.

As the ministerial order has not yet been published, the final implementation dates have not yet been determined.

Veri*Factu and Electronic Invoicing – Two Different Systems

In practice, the two reforms are frequently confused.

However, they are in fact two separate and independent legal frameworks.

1. Veri*Factu

Veri*Factu is based on

• Law 11/2021 (Anti-Fraud Law)
• Royal Decree 1007/2023

This legislation does not concern electronic invoices themselves.

Instead, it establishes requirements for the invoicing software used by businesses and professionals.

In particular, the software must

• prevent improper manipulation of records,
• record all modifications,
• generate unalterable records and
• be capable of transmitting data to the Spanish Tax Agency (Agencia Tributaria) when required.

2. Electronic Invoicing

Electronic invoicing, on the other hand, is based on

• Ley Crea y Crece
• Royal Decree 238/2026

Here, the focus is not on the software itself, but on the electronic exchange of structured invoices between businesses and self-employed professionals.

Deadlines for Veri*Factu

Binding deadlines now apply to the introduction of compliant invoicing software.

Companies

Mandatory use from 1 January 2027

Other Businesses and Self-Employed Professionals

Mandatory use from 1 July 2027

These deadlines were extended at the end of 2025 by Royal Decree-Law 15/2025.

Existing E-Invoicing Obligations

Irrespective of the future general obligation, there are already various situations in which electronic invoices are mandatory.

These include in particular:

• invoices issued to public administrations,
• certain public contracting authorities,
• specific cases provided for by law.

Overview of the Legal Framework

Developments at European Level

The digitalisation of VAT is also progressing at European level.

With the VAT in the Digital Age (ViDA) reform package, the European Union plans to gradually expand the use of electronic invoicing and digital reporting requirements for cross-border transactions.

Spain is among the EU countries at the forefront of this process.

Conclusion

The introduction of electronic invoicing represents an important step towards the digitalisation of business activity in Spain.

While fixed implementation dates in 2027 have already been established for compliant invoicing software (Veri*Factu), the start of the general mandatory e-invoicing regime still depends on the publication of the outstanding ministerial order.

Companies and self-employed professionals should use the remaining time to prepare their internal processes and invoicing software for both reforms well in advance.

As lawyers, tax advisors and a registered PAE, our firm will be pleased to assist you in analysing your specific situation, carrying out the relevant administrative procedures and preparing and filing the necessary tax returns. Further information about our services for self-employed professionals and businesses can be found in the section Businesses.

If you are interested in our services or have specific questions regarding this topic, please do not hesitate to contact us by email or telephone.

Author:

Lisa Wörfel
Tax Advisor
info@sspartners.es
Tel: (+34) 951 12 13 06
Facebook I LinkedIn I Amazon