For years, "e-invoicing" in Spain meant one thing: invoicing the public administration through FACe, the government's e-invoicing portal, in the Facturae format. That's changing. Under the Crea y Crece Act, e-invoicing is no longer just for public-sector suppliers: it becomes mandatory between companies, freelancers and sole traders, which covers 99% of the invoices issued in Spain.
Because the rules have been rolled out in stages (the act in 2022, the regulation in March 2026 and the technical order in October 2026), there's a lot of outdated information around. Here is where things really stand as of October 2026, what changes in your operations and how we're handling it with our clients.
What an e-invoice is (and what it isn't)
An e-invoice, as this law defines it, is an invoice issued and received in a structured format that software can read and process automatically: Facturae (XML), UBL, CII or EDIFACT. A PDF sent by email is not an e-invoice for these purposes, even though that's what most people have always called it.
The underlying idea is that invoices travel from one piece of software to another without anyone retyping them, and that both parties (and the tax authorities) know their status: whether it has been accepted, rejected and, above all, paid. That's the real goal of the law: reducing late payments and getting reliable data on payment terms between companies.
When Spain's mandatory e-invoicing takes effect
Royal Decree 238/2026 of March 25 (published in Spain's Official State Gazette, the BOE, on March 31, 2026) approves the regulation and sets deadlines based on a ministerial order governing the public invoicing platform. That order, Order HAC/1028/2026, came into force on October 6, 2026, and the deadlines run from that date:
| Who | Mandatory from | Deadline |
|---|---|---|
| Companies and professionals with turnover above €8 million | October 6, 2027 | 12 months after the order |
| All other companies, freelancers and sole traders | October 6, 2028 | 24 months after the order |
An important detail: the obligation to receive e-invoices also starts on those dates. So an SME with low turnover that buys from large companies will receive e-invoices from October 2027 and must be able to process them. It pays to be ready before your own deadline.
What exactly the regulation requires
- Issue invoices to other companies and professionals in a structured electronic format.
- Receive e-invoices from your suppliers and be able to read them, store them and make them available to the tax authorities.
- Report the status of each invoice: commercial acceptance or rejection, and actual payment with its date. This part is new for almost everyone.
- Do all this through the AEAT's public invoicing platform or through certified private platforms, which must be interconnected. If you use a private one, a copy of every invoice still reaches the public platform.
Sales to end consumers (B2C) are outside this obligation. There, the usual invoice or receipt is still valid, as long as it's generated with software that complies with Verifactu.
E-invoicing and Verifactu: two obligations, one piece of software
These are the two rules we get asked about most, and it's worth keeping them apart:
| Verifactu | B2B e-invoicing | |
|---|---|---|
| What it governs | How software generates and records each invoice (hash, QR code, submission to the AEAT) | The format in which an invoice is sent to another company and how its status is reported |
| Who it affects | Everyone who invoices with software (B2B and B2C) | Only transactions between companies and professionals |
| Dates | January 1 and July 1, 2027 (a further announced postponement is pending) | October 6, 2027 and October 6, 2028 |
| Legislation | Act 11/2021 and RD 1007/2023 | Act 18/2022 and RD 238/2026 |
The good news is that both are solved in the same place: your invoicing software or your ERP. Choose or adapt it properly once and you cover both.
What changes day to day for an SME
More than you might think, and almost all of it for the better if your systems are integrated:
- No more typing in supplier invoices. You receive them in a structured format and they flow straight into the ERP, with their line items, taxes and due dates. It's what we achieve today with invoice OCR, but without reading errors.
- You'll have to manage statuses. Accept, reject and mark as paid every invoice you receive, on time. That requires a clear approval workflow, even a simple one.
- Your suppliers will see when you pay them. And you'll see when your customers pay you. Late payment stops being invisible.
- Your online store and POS count too when the buyer is a business. If you sell B2B online, integrating your store with your ERP goes from nice-to-have to essential.
How to prepare your company: what we do with our clients
- Invoice map: how many invoices you issue and receive each month, from which systems, and what percentage is B2B.
- Centralize in the ERP: a single system that issues, receives and records. With Dolibarr, Odoo or FacturaScripts, this is achievable for an SME without a big investment.
- Choose your sending channel: the AEAT's public platform (free) or a private platform, depending on your volume and what your large customers already use.
- Define the approval workflow for incoming invoices: who accepts, who rejects, and within how many days.
- Integrate everything outside the ERP: online store, POS, customer portal. Every channel that issues invoices has to end up in the ERP.
- Test with a real customer and a real supplier before the deadline, not after.
A company that reaches October 2028 with an integrated ERP and a defined approval workflow won't notice the change. One that gets there with Excel, PDFs and emails will notice all of it.
Penalties
The Crea y Crece Act provides for fines of up to €10,000 for companies that don't offer their customers the option of receiving e-invoices or don't give them access to those invoices for the legally required period. And fines aside, a supplier that can't issue e-invoices will simply be unable to get paid by many of its customers.
How we help
At Interconecta we've spent more than twelve years implementing ERPs and connecting invoicing systems, online stores and third-party platforms for SMEs. With e-invoicing we do what we've always done: we analyze how you invoice, propose the simplest way to comply with Verifactu and e-invoicing at the same time, and leave it up and running, integrated, with your team trained. If you want to know where you stand, ask us for a free assessment.
Want to reach 2027 with everything in place?
We review your invoicing system for free, tell you what it's missing for Verifactu and e-invoicing, and give you a fixed-price proposal.
Talk to Interconecta