B2B E-Invoicing in Spain: Timeline and Preparation

Regulatory review: 25 August 2026. Royal Decree 238/2026 has been published, but the general obligation did not automatically begin in 2026. Its effective application is calculated from the entry into force of the ministerial order that must complete the technical rules for the public solution.

What Royal Decree 238/2026 regulates

The decree develops the mandatory business-to-business e-invoicing system provided for by Law 18/2022. As a general rule, it will cover B2B invoices where the business or professional recipient has its place of business, a permanent establishment or, failing that, its domicile or habitual residence in Spain, provided that the transaction is addressed to that location.

The system includes a public e-invoicing solution and interoperable private platforms. In addition to issuing and receiving an invoice electronically, the framework introduces communications concerning invoice status and payment. Exceptions and transitional rules must be checked for the specific transaction and taxpayer.

When it becomes mandatory

The fourth final provision does not set a fixed calendar date. Effective application is linked to the future implementing ministerial order:

• Twelve months after the order enters into force: businesses and professionals whose turnover exceeded €8 million in the preceding calendar year.
• Twenty-four months after the order enters into force: the remaining covered businesses and professionals.

It is therefore inaccurate to state that every business became subject to the obligation in 2026. The actual date must be calculated when the ministerial order is published and enters into force.

B2B e-invoicing and VeriFactu are different projects

B2B e-invoicing governs the format, transmission, receipt and certain status information for invoices exchanged between businesses and professionals. The invoicing-system regulation —often referred to as VeriFactu— governs how certain systems that generate invoicing records operate.

The frameworks interact, but they do not have the same purpose or timetable. A business may need to adapt its invoicing system to the latter regulation before B2B e-invoicing becomes mandatory for it.

What businesses can prepare now

1. Classify transactions: separate domestic B2B, B2C, public-sector and international transactions.
2. Map the process: document issuance, receipt, approval, rejection, correction, payment and retention.
3. Review master data: tax identifiers, legal names, addresses, payment terms and internal owners.
4. Question the supplier: supported formats, interoperability, connection to the public solution and contractual implementation schedule.
5. Assign responsibilities: determine who validates invoices, communicates incidents and monitors payment status.
6. Monitor the ministerial order: do not set a final implementation date without verifying its publication and entry into force.

Official source

The applicable text and timing rules are available in Royal Decree 238/2026 in Spain's Official State Gazette, particularly its fourth final provision.

Useful preparation means organising data and processes so the right solution can be implemented once the legally determinable timetable is known, rather than purchasing a tool on the basis of an unsupported date.