E-invoicing between businesses in Spain stopped being a promise on 31 March 2026, when the BOE (Boletín Oficial del Estado, the official state gazette) published Royal Decree 238/2026 of 25 March (Real Decreto 238/2026), which implements the system of mandatory electronic invoicing between businesses and professionals provided for in Law 18/2022, “Crea y Crece” (Ley 18/2022 de creación y crecimiento de empresas, the business creation and growth law). The regulation has been in force since 20 April 2026, but the obligation is not yet enforceable: it takes effect 12 months after the implementing ministerial order comes into force for companies with a turnover of more than €8 million, and 24 months after it for everyone else. The draft order sets 1 October 2026 as its date of entry into force, which would put the dates at 1 October 2027 and 1 October 2028. This guide explains, as at 16 September 2026, how the system works, what has to change in the ERP of an industrial or agri-food company and why it is not the same thing as Verifactu (Spain’s separate rules on invoicing software).
Where the obligation comes from
Article 12 of Law 18/2022 amended Article 2 bis of Law 34/2002 (Ley 34/2002), the LSSI (Spain’s e-commerce act), to require all businesses and professionals to issue, send and receive electronic invoices in their commercial dealings with other businesses and professionals, and to report on the statuses of those invoices. The stated aim is to tackle late payment: with structured invoices and reported statuses, the public authorities can measure actual payment periods. The law left the detail to a regulation, which took almost four years to arrive: Royal Decree 238/2026.
How Spain’s B2B e-invoicing system works
The regulation sets up a hybrid system:
- A public e-invoicing solution, run by the Spanish Tax Agency (Agencia Tributaria) and free of charge, which allows invoices to be issued, sent and received and statuses to be reported. It is the default route for anyone who does not sign up to another.
- Private platforms for exchanging electronic invoices, which must meet interoperability, security and continuity requirements and be interconnected with one another and with the public solution: an invoice issued from any platform must be able to reach any recipient, wherever they are.
- A copy of every invoice issued through a private platform must be sent to the public solution in Facturae format, so that the public authorities have all the invoices and their statuses.
The accepted formats are structured and syntactically defined: Facturae (the Spanish XML format already used for invoicing the public sector), UBL, CII (Cross Industry Invoice) and EDIFACT, all aligned with the European standard EN 16931. A PDF, even a signed one, is not an electronic invoice for these purposes.
Invoice statuses
The new feature with the greatest effect on internal processes is the obligation on the recipient to report the statuses of every invoice received: commercial acceptance or rejection, and actual payment in full, with its date. The regulation sets a maximum period for reporting each status from the moment it occurs, and those statuses travel to the public solution, which uses them to calculate average payment periods. For companies with a turnover of less than €8 million, the obligation to report statuses is deferred for longer than the obligation to issue and receive, according to the timetable in the draft order.
For an ERP this means that the supplier invoice approval workflow, which today is internal, has to send messages outwards: when purchasing accepts an invoice, when it rejects one and when treasury pays it.
Timeline: what is known as at 16 September 2026
| Milestone | Date | Status |
|---|---|---|
| Law 18/2022, “Crea y Crece” | BOE, 29 Sep 2022 | In force |
| Royal Decree 238/2026 (regulation) | BOE, 31 Mar 2026; in force 20 Apr 2026 | In force |
| Implementing ministerial order (formats, public solution, platforms) | Draft with entry into force planned for 1 Oct 2026 | Not yet published in the BOE |
| Obligation for companies with turnover > €8 million | 12 months from the order: 1 Oct 2027 if confirmed | Subject to the order |
| Obligation for all other businesses and professionals | 24 months from the order: 1 Oct 2028 if confirmed | Subject to the order |
| Invoice statuses for those with turnover < €8 million | Additional period provided for in the draft order | Subject to the order |
The two dates in 2027 and 2028 depend on the order being published with the planned entry into force; if it is delayed, they move back automatically. What does not depend on anything is that the regulation is already in force and that platforms and ERPs have to be ready in advance.
What changes in an industrial company’s ERP
- Structured issuing: the ERP must generate the invoice in one of the accepted formats, with all the mandatory fields of the invoicing regulation and of EN 16931, not just print it.
- Connection to a platform or to the public solution: sending the invoice, receiving the acknowledgement and, if a private platform is used, sending the Facturae copy to the public solution.
- Structured receipt: supplier invoices arrive as XML, not as PDF; the ERP must read them, validate them, record them and route them for approval without anyone keying them in.
- Outbound statuses: acceptance, rejection and payment must leave the internal workflow for the platform within the set period, with a date.
- Identification of trading partners: each customer and supplier needs its identifier in the exchange system and its destination platform.
- Retention: the electronic invoice is kept in its original format with its traceability; the PDF is a rendering, not the original.
- Coexistence with invoicing the public sector: anyone who already invoices public entities through FACe (the central government’s e-invoicing entry point) using Facturae is halfway there; the format is the same and the channel changes.
- Integration with Verifactu: they are different systems, with different purposes, but they share source data; the design must avoid recording the invoice twice.
B2B e-invoicing and Verifactu: two different obligations
They are often confused, and it is worth separating them:
| B2B e-invoicing (RD 238/2026) | Verifactu (RD 1007/2023) | |
|---|---|---|
| What it governs | The exchange of the invoice between companies, and its statuses | The software that generates the invoice, and its records |
| Who it binds | Businesses and professionals in transactions with other businesses and professionals | Anyone who uses a computerised invoicing system, except those in the SII (the VAT Immediate Supply of Information system) and the foral territories (the Basque Country and Navarre) |
| Format | Facturae, UBL, CII, EDIFACT | Any; adds a QR code and the Verifactu wording |
| Where the data goes | Exchange platforms and the Tax Agency’s public solution | Invoicing records submitted to, or kept for, the Tax Agency |
| When | 12 and 24 months from the ministerial order (expected in 2027 and 2028) | 1 Jan 2027 (corporate income tax payers) and 1 Jul 2027 (everyone else) |
An ERP has to comply with both, and the sensible approach is to tackle them in the same adaptation project. We set out the Verifactu requirements for an in-house development in Verifactu in 2027: what business management software or a custom ERP must comply with.
Penalties
Failure to comply with the e-invoicing obligation is penalised under Law 18/2022 with fines of up to €10,000 for not offering the customer an electronic invoice or not allowing access to it, in addition to the consequences for invoicing and late payment that the law itself lays down. And there is an effect that comes before any penalty: a large company bound from 2027 will stop accepting PDFs from its suppliers, and anyone who cannot issue in a structured format will have a problem getting paid before it has a legal problem.
How CEDESA does it
CEDESA builds e-invoicing into the custom management systems it develops and maintains for industrial and agri-food companies, such as the ERPs with traceability that we describe in ERP software for the meat industry and abattoirs. We have been generating Facturae invoices for the public sector for years, and adapting to RD 238/2026 consists of taking that same structured format into the workflow with other companies, connecting the exchange platform and making the statuses come out of the approval flow itself. With ISO 27001, ISO 9001 and ISO 56001 certification, the change is made with version control, testing and documentation, which is what the Verifactu self-declaration (declaración responsable) will also require.
Frequently asked questions about mandatory B2B e-invoicing
When does e-invoicing between businesses become mandatory in Spain?
Royal Decree 238/2026 has been in force since 20 April 2026, but the obligation becomes enforceable 12 months after the implementing ministerial order comes into force for companies with a turnover of more than €8 million, and 24 months after it for everyone else. The draft order provides for entry into force on 1 October 2026, which would put the dates at 1 October 2027 and 1 October 2028; as at 16 September 2026 the order has not been published in the BOE.
Is a signed PDF a valid electronic invoice?
Not for the purposes of RD 238/2026. The electronic invoice must be in an accepted structured format (Facturae, UBL, CII or EDIFACT), in line with the European standard EN 16931, so that it can be processed automatically and its statuses reported.
What are invoice statuses and who reports them?
They are commercial acceptance or rejection, and actual payment in full, with its date. They are reported by the recipient of the invoice through its platform or the public solution, within the period set by the regulation, and the public authorities use them to measure payment periods.
Is B2B e-invoicing the same thing as Verifactu?
No. Verifactu (RD 1007/2023) governs the software that generates invoices and its records, with dates of 1 January and 1 July 2027; B2B e-invoicing (RD 238/2026) governs the exchange of the invoice between companies and its statuses, with dates expected in 2027 and 2028. An ERP must comply with both.
What has to change in my ERP for B2B e-invoicing?
It has to issue in a structured format, connect to a private platform or to the Tax Agency’s public solution, send the Facturae copy when it uses a private platform, receive and process XML invoices from suppliers, report the acceptance, rejection and payment statuses on time, identify each trading partner and keep the invoice in its original format.
Conclusion
E-invoicing between businesses now has its regulation and lacks only the ministerial order to have firm dates: 2027 for large companies and 2028 for everyone else, if 1 October 2026 is confirmed as the date of entry into force. For an industrial ERP it means issuing and receiving in a structured format, connecting to a platform and making statuses come out of the approval workflow, all of it alongside Verifactu, which arrives first. If you want to know what yours is missing, tell us how you invoice and how you approve supplier invoices today.