ERP & Business Management 6 min read

Spain's mandatory B2B e-invoicing: what it is, when it starts and how to prepare

E-invoicing Crea y Crece Act RD 238/2026 B2B SMEs

Spain's «Crea y Crece» (Create and Grow) Act requires every invoice between companies, freelancers and sole traders to be electronic. The regulation has been approved and the clock started ticking in October 2026. Here are the exact dates, what changes in your day-to-day work and what your invoicing software needs to do.

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out in stages (the act in 2022, the regulation in March 2026 and the technical order in October 2026), there's a lot of outdated information around.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:

WhoMandatory fromDeadline
Companies and professionals with turnover above €8 millionOctober 6, 202712 months after the order
All other companies, freelancers and sole tradersOctober 6, 202824 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:

VerifactuB2B e-invoicing
What it governsHow 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 affectsEveryone who invoices with software (B2B and B2C)Only transactions between companies and professionals
DatesJanuary 1 and July 1, 2027 (a further announced postponement is pending)October 6, 2027 and October 6, 2028
LegislationAct 11/2021 and RD 1007/2023Act 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

  1. Invoice map: how many invoices you issue and receive each month, from which systems, and what percentage is B2B.
  2. 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.
  3. 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.
  4. Define the approval workflow for incoming invoices: who accepts, who rejects, and within how many days.
  5. Integrate everything outside the ERP: online store, POS, customer portal. Every channel that issues invoices has to end up in the ERP.
  6. 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

FAQ: mandatory e-invoicing in Spain

What is mandatory e-invoicing in Spain?

It's the obligation, established by Act 18/2022 («Crea y Crece») and implemented by Royal Decree 238/2026, to issue and receive all invoices between companies and professionals in a structured electronic format, and to report their status (acceptance, rejection and payment). A PDF sent by email doesn't count as an e-invoice.

When does mandatory e-invoicing take effect in Spain?

From October 6, 2027 for companies and professionals with turnover above €8 million, and from October 6, 2028 for everyone else. The deadlines run from the entry into force of Order HAC/1028/2026 on October 6, 2026.

Does it apply to freelancers and sole traders?

Yes. Freelancers and sole traders who invoice other companies or professionals must issue and receive e-invoices from October 6, 2028, unless their turnover exceeds €8 million, in which case the date is October 2027.

Do invoices to consumers also have to be electronic?

No. The Crea y Crece obligation only applies to transactions between businesses and professionals (B2B). Sales to end consumers are excluded, although the software that generates those invoices must still comply with Verifactu.

Which e-invoice formats are accepted?

The structured formats recognized in the regulation: Facturae (XML), UBL, CII and EDIFACT. The AEAT's public platform works with Facturae, and private platforms must be able to convert between formats.

Do I need to change my invoicing software?

It depends on whether your current software will support issuing and receiving invoices in a structured format and reporting their status. Ask your provider. If you use an open-source ERP such as Dolibarr, Odoo or FacturaScripts, it can be solved with modules and configuration, without switching systems.

What happens if I don't comply?

The law provides for fines of up to €10,000 for anyone who doesn't offer e-invoices to their customers or doesn't give them access to them. In practice, being unable to issue e-invoices will also make it harder to get paid by customers who already require them.

Let’s talk about your case

Tell us about your situation and we’ll explain how we would solve it: a free assessment and a fixed-price proposal, with no obligation. We reply within 24 hours.