Mandatory e-invoicing in Spain: RD 238/2026 explained

For years, mandatory e-invoicing in Spain was a legal promise with no fine print. Not anymore. Royal Decree 238/2026, of 25 March (reference BOE-A-2026-7295, published in the Official State Gazette No. 79 on 31 March 2026) is the actual regulation that implements mandatory B2B e-invoicing in Spain. If you read a guide that mentioned a “2025 deadline” for large companies, forget it: that calendar was never correct. Here is what the regulation actually says, with no invented dates.

For context: the Boletín Oficial del Estado (BOE) is Spain’s official state gazette, the legal record where a rule only becomes binding once published. That detail matters a lot in this story.

What actually changes in 2026: the regulation now exists, and it’s RD 238/2026

Until 2026 there was only a legal mandate in the abstract. Spain’s “Crea y Crece” law (the Business Creation and Growth Act) set the obligation in principle, but the “how” depended on implementing regulation that never arrived. That implementing text is now published.

RD 238/2026, of 25 March, develops mandatory e-invoicing between businesses and professionals and amends the invoicing regulation approved by RD 1619/2012. It is the missing piece: it defines formats, invoice statuses, deadlines and the role of the public invoicing solution.

The takeaway for your organization, whatever its size: the obligation now has a regulation and its compliance clock is already running. That gives you room to prepare properly, not room to ignore it.

The exact legal chain: from Law 18/2022 to article 2 bis of Law 56/2007

The legislative chain is short, and it’s worth knowing because it explains why the obligation is solid rather than a draft.

• Law 18/2022, on business creation and growth (the “Crea y Crece” act), in its article 12, gave new wording to article 2 bis of Law 56/2007 (the Information Society Promotion Measures Act, LISI) — an article originally introduced by Law 25/2013 — to extend mandatory e-invoicing to all B2B transactions.
• That article 2 bis is what imposes mandatory e-invoicing on transactions between businesses and professionals.
• RD 238/2026 is the regulation that develops article 2 bis and translates the obligation into concrete technical requirements.

The scope is B2B: transactions between businesses and professionals (in Spain, “professionals” includes self-employed workers, or autónomos). Invoices to end consumers (B2C) fall outside this specific obligation. If you invoice other companies or self-employed workers, it applies to you; if you only invoice private individuals, this rule doesn’t change how you issue invoices.

Entry into force vs effective application: why the clock didn’t run until October 2026

Here is the nuance almost everyone confuses. It’s one thing for the regulation to enter into force, and quite another for you to be required to issue structured electronic invoices.

RD 238/2026 entered into force on 20 April 2026 (20 days after publication, per final provision four.1). But its effective application is deferred: the compliance deadlines do not count from that entry into force.

Under final provision three, the deadlines start running from the entry into force of the ministerial order approving the public invoicing solution. And that’s the crucial point:

In plain terms: the obligation is real, regulated and now has a calendar: October 2027 for businesses with turnover above 8 million euros and October 2028 for everyone else.

Calendar by revenue tier: 12 months (above 8M EUR) and 24 months (everyone else)

The regulation does confirm the structure of the calendar, even if not the start date. There are two tiers based on the prior calendar year’s turnover.

Both deadlines are 12 and 24 months, and their start depends on the ministerial order, now published.

One important point: this obligation does not distinguish by organization size beyond the turnover threshold. It applies to businesses and professionals of any size operating in B2B. The only relevant cut-off is the 8-million-euro line, and only to decide whether your deadline is 12 or 24 months.

The calendar of the ministerial order

With the start fixed, the calendar is concrete: Order HAC/1028/2026 of 2 October was published in the BOE on 5 October 2026.

The second transitional provision of RD 238/2026 adds a safeguard for the first tier: during the 12 months following October 2027, businesses above 8 million euros must accompany the electronic invoice with a PDF that ensures its legibility, unless the recipient accepts the original format. That PDF is not sent to the public solution.

Admitted formats: CII, UBL, EDIFACT and Facturae under EN 16931

Article 7.1 of RD 238/2026 defines four admitted structured syntaxes, all compliant with the European standard EN 16931:

• CII (Cross Industry Invoice)
• UBL (Universal Business Language)
• The EDIFACT invoice message
• The Facturae message (Spain’s national XML invoice format)

The common thread is that these are structured formats: machine-readable, tagged data that a system can process without human intervention. That’s the fundamental shift from today’s practice.

If you operate, or plan to operate, across Europe, EN 16931-based interoperability connects directly to the Peppol ecosystem. We cover this in the guide to Peppol and e-invoicing in Europe.

Mandatory status reporting: acceptance/rejection and payment, within 4 days

This is one of the changes with the most operational impact, and it often goes unnoticed. RD 238/2026 doesn’t only regulate how you issue invoices: it also requires you to report the status of each invoice.

Article 10 makes two statuses mandatory:

1. Commercial acceptance or rejection of the invoice, with its date.
2. Full effective payment, with its date.

All other possible statuses are optional. But those two must always be reported.

And there’s a deadline. Article 10.3 sets a maximum of 4 calendar days, excluding Saturdays, Sundays and national public holidays, to report each mandatory status.

That said, when this reporting starts to be required depends on who you are. Status reporting: October 2027 for businesses above €8 million; October 2028 for companies at or below €8 million; and, for self-employed individuals and income-attribution entities at or below €8 million, twelve months later, around October 2029 (third transitional provision of RD 238/2026). Until then it is voluntary for them.

The free public solution from the tax agency: what it is and when it activates

The system rests in part on a public invoicing solution developed and managed by Spain’s tax agency (the AEAT, Agencia Estatal de Administración Tributaria). It’s free and designed as the lowest common denominator so any organization can comply.

Two concrete facts worth keeping in mind:

• The public solution will be free, developed and managed by the tax agency.
• It will be available at least two months before the first effective application of the obligation.

And here the circle closes with the clock point: it is precisely the ministerial order regulating this public solution, Order HAC/1028/2026 published on 5 October 2026, that triggers the countdown of the 12 and 24 months.

B2B e-invoicing (RD 238/2026) is not VeriFactu (RD 1007/2023): two different rules

This is the most common misunderstanding. VeriFactu and mandatory B2B e-invoicing are two different obligations, with different regulations and different subject matter.

They operate on different planes: one governs how the invoice is exchanged between businesses; the other governs what the software that generates it must be like. You may have to comply with both. For the detail on VeriFactu, see the VeriFactu guide for freelancers and businesses.

VeriFactu timeline (updated 6 October 2026). The rule in force, Royal Decree-law 15/2025 of 2 December, sets the adaptation deadline before 1 January 2027 for Corporate Income Tax payers and before 1 July 2027 for everyone else. On 5 October 2026 Spain’s Ministry of Finance announced it will postpone the obligation to October 2028, to align it with mandatory B2B e-invoicing. That postponement has not yet been published in the BOE (Spain’s official gazette).

How to prepare today: an actionable checklist

With time still left before your deadline, there is still no excuse to wait. Preparation depends on your operations being ready when the date arrives. Here’s the work you can get ahead of today.

If you still invoice by hand or from a spreadsheet, start with the basics and build from there. You can test formats and mandatory fields with the invoice generator, and if you work as a self-employed professional in Spain, review the guide to invoicing as an autónomo in Spain.

Frequently asked questions

Does a regulation for mandatory B2B e-invoicing in Spain already exist?

Yes. Royal Decree 238/2026, of 25 March (BOE-A-2026-7295, Official State Gazette No. 79 of 31 Mar 2026), develops the mandatory e-invoicing system between businesses and professionals and amends the regulation approved by RD 1619/2012.

When will B2B e-invoicing become mandatory?

RD 238/2026 entered into force on 20 April 2026, but effective application is deferred: 12 months for turnover above 8 million euros and 24 months for everyone else, counted from the ministerial order that approves the public solution. That order, Order HAC/1028/2026 of 2 October, was published in the BOE on 5 October 2026: the obligation arrives in October 2027 for businesses with turnover above 8 million euros and in October 2028 for everyone else.

What deadlines does the ministerial order start, and when does the clock start?

Order HAC/1028/2026 of 2 October, published in the BOE on 5 October 2026, regulates the AEAT’s public e-invoicing solution and starts the clock: the obligation arrives in October 2027 for businesses with turnover above €8 million and in October 2028 for everyone else.

Which e-invoice formats are admitted?

Article 7.1 admits CII, UBL, the EDIFACT invoice message and the Facturae message, all compliant with the European standard EN 16931. A PDF by email is not a valid structured format.

Is VeriFactu the same as mandatory B2B e-invoicing?

No. VeriFactu is governed by RD 1007/2023 (amended by RD 254/2025) and concerns invoicing software systems. Mandatory B2B e-invoicing is governed by RD 238/2026 and deals with the structured exchange of invoices between businesses and status reporting.

Will I have to report when I accept or pay an invoice?

Yes. Article 10 requires reporting commercial acceptance/rejection and full effective payment, with their dates, within a maximum of 4 calendar days (excluding Saturdays, Sundays and national public holidays).