Spain sets rules for mandatory B2B eInvoicing

Spain has taken a major step towards mandatory business‑to‑business (B2B) eInvoicing.

On 31 March 2026, Spain published Royal Decree 238/2026 in the Official State Bulletin (BOE). This Decree implements the eInvoicing obligations introduced under the Law on Business Creation and Growth (Ley de Creación y Crecimiento de Empresa).

The new rules define who must issue electronic invoices, which transactions are covered, the technical formats that must be used and when the obligations will apply. For businesses trading in Spain, this is a clear signal: B2B invoicing processes will need to change

Who must comply with Spain’s eInvoicing rules

The obligation applies to B2B transactions where both parties are connected to Spain.

In scope are transactions between businesses that:

• Are headquartered in Spain
• Are permanently established in Spain
• Have their domicile or habitual residence in Spain

These businesses must already be required to issue invoices under Royal Decree 1619/2012, which governs Spanish invoicing obligations.

If a transaction meets these criteria, the invoice must be issued, transmitted and delivered in electronic format, once the rules become effective.

Which invoices are out of scope

Not all invoices fall under the mandatory eInvoicing requirement.

The Decree explicitly excludes simplified invoices issued under Article 4 of Royal Decree 1619/2012. These typically apply to low‑value transactions below the specified thresholds.

However, there is an important exception:

• If the customer requests a fully detailed invoice, the exemption no longer applies
• In that case, the invoice must be issued as a compliant electronic invoice, in line with Article 7.2 of Royal Decree 1619/2012

In practice, this means businesses cannot rely on simplified invoicing if their customer asks for full invoice detail.

How electronic invoices must be exchanged

Spain will allow a hybrid exchange model, using both public and private platforms.

Businesses may issue eInvoices through:

• Public eInvoicing platforms, or
• Private eInvoicing platforms

However, there is a key additional requirement for private platforms.

If a business uses a private platform, it must:

• Send a faithful electronic copy of each invoice
• In UBL (Universal Business Language) format
• To the public eInvoicing platform, at the same time

These copies, together with invoice status information, will enable the Spanish tax authorities to:

• Carry out tax control activities
• Monitor payment terms
• Support statistical analysis

Approved eInvoicing formats

Electronic invoices must comply with European standard EN 16931.

Spain has confirmed four permitted formats:

• Cross Industry Invoice (CII)
• Universal Business Language (UBL)
• Electronic Data Interchange for Administration, Commerce and Transport (EDIFACT)
• Facturae (Spain’s national eInvoicing format)

eInvoicing platforms must ensure full interoperability, including the ability to convert invoices into all supports formats where required.

New invoice status and payment reporting obligations

The Decree introduces mandatory invoice lifecycle reporting, which goes beyond invoice issuance.

Recipients of electronic invoices must communicate the following information back to the issuer:

• Acceptance or rejection of the commercial invoice, including the respective date
• Full payment details and the date of effective payment.

Recipients may also report:

• Invoices assigned to third parties for collection or payment
• The status of partially paid invoices

Reporting deadlines

Invoice status updates must be reported:

• Within a maximum of four calendar days of the status change
• Saturdays, Sundays and national public holidays are excluded from the calculation

Both public and private eInvoicing platforms must support these reporting requirements and comply with the technical specifications set out in the Decree

When the rules enter into force

The Decree formally enters into force:

• 20 days after publication in the Official State Bulletin.

However, effective application is deferred until the Regulation governing public eInvoicing platform enters into force under Law 18/2022. Until that happens, businesses are not yet required to comply operationally.

Phased implementation timelines

Spain will introduce mandatory B2B eInvoicing in stages, based on turnover.

Phase 1: Large businesses

• Applies within 12 months of effective application
• Covers entrepreneurs and professionals with turnover exceeding €8 million in the previous year

During this phase:

• eInvoices are mandatory
• PDF copies must accompany electronic invoices where the recipient is not yet in scope.

Phase 2: All remaining businesses

• Applies within 24 months of effective application
• Covers all other businesses subject to the invoicing rules

At this point, mandatory B2B eInvoicing becomes universal for in‑scope Spanish transactions.

What this means for global businesses

Spain’s approach reflects a broader global trend: eInvoicing is becoming a regulatory infrastructure, not just a digital format change.

For multinational groups, the key challenges will be:

• Identifying Spanish in‑scope entities and transactions
• Supporting multiple invoice formats and platform models
• Managing invoice status and payment reporting within strict deadlines
• Aligning Spain’s requirements with other national eInvoicing mandates already in force

Businesses that prepare early will be best placed to manage compliance, reduce manual effort and avoid disruption as the deadlines approach.

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