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, but the compliance clock hasn’t started. 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 still isn’t running (as of July 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 and regulated, but no one can yet give you an official deadline on the calendar. Anyone who gives you a firm date is estimating from a draft that isn’t published yet.

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.

Tier	Turnover (prior year)	Deadline	Counted from
Tier 1	Above 8,000,000 EUR	12 months	Entry into force of the ministerial order
Tier 2	Everyone else (8,000,000 EUR or below)	24 months	Entry into force of the ministerial order

Both deadlines are firm in duration (12 and 24 months). What is not firm is their start date, because it depends on a ministerial order that has not yet been 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 the draft ministerial order sets (provisional)

Although the start date isn’t firm, it isn’t a mystery either: the draft ministerial order that governs the public solution already writes a concrete calendar. It was published on 16 April 2026 and its public consultation closed on 8 May 2026. Its final provision provides for the order to enter into force on 1 October 2026, and from there it fixes three tiers.

Date (provisional)	What it requires	How it’s counted
1 Oct 2026	Entry into force of the ministerial order: the deadline countdown begins	Final provision (draft)
1 Oct 2027	Mandatory e-invoice issuance for those who invoiced more than 8 million euros the previous year	+12 months
1 Oct 2028	Mandatory issuance for everyone else (legal entities and self-employed with turnover of 8 million EUR or below)	+24 months
1 Oct 2029	Obligation to report invoice statuses (arts. 10 and 12) for individuals and income-attribution entities with turnover of 8 million EUR or below	+36 months

A nuance almost no guide captures: the 2029 tier does not delay e-invoicing for the self-employed. A self-employed worker below 8 million euros would have to issue electronic invoices from October 2028 (the “everyone else” tier); the only thing pushed to October 2029 is the obligation to report the statuses of those invoices (acceptance/rejection and payment). It’s breathing room on that one piece, not on the whole obligation.

During the first year of the above-8M-EUR tier — between October 2027 and October 2028 — the draft additionally requires each electronic invoice to be accompanied by a legible PDF, unless the recipient expressly and voluntarily agrees to receive it only in its structured format.

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 follows the provisional calendar in the draft ministerial order we saw above: from October 2027 for those above 8 million euros, and not before October 2029 for the self-employed and income-attribution entities below that threshold.

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

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 approving this public solution that triggers the countdown of the 12 and 24 months. That’s why, until that order is published in the official gazette, there is no firm start date.

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.

	B2B e-invoicing	VeriFactu
Regulation	RD 238/2026	RD 1007/2023 (amended by RD 254/2025)
Subject	Structured exchange of invoices between businesses and status reporting	Requirements for invoicing software systems
Scope	B2B transactions	Software that issues invoices

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.

How to prepare today without firm dates: an actionable checklist

Having no start date is no excuse to wait. Preparation doesn’t depend on the ministerial order: it depends on your operations being ready when it arrives. Here’s the work you can get ahead of today without inventing deadlines.

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.

The goal isn’t just to comply, but to make compliance cost you zero hours of manual work. Frihet handles structured formats and status reporting natively, for organizations of any size. When the ministerial order sets the start, your operations will already be ready. You can see the full approach on the Frihet e-invoicing page.

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. Those deadlines count from the entry into force of the ministerial order that approves the public solution, which as of 10 July 2026 has still not been published in the official gazette.

What dates does the draft ministerial order set, and when does the clock start?

The draft ministerial order that governs the public solution (published on 16 April 2026, with the public consultation closed on 8 May) provides for its entry into force on 1 October 2026. The deadlines would then run from that date: 1 October 2027 for those who invoiced more than 8 million euros the previous year, 1 October 2028 for the rest of businesses and self-employed, and 1 October 2029 for the obligation to report invoice statuses for individuals and income-attribution entities with turnover of 8 million euros or below. These are draft dates: they will not be firm until the order is published in the official gazette.

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).