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This article was last updated on Jun 22, 2026, following the publication of the draft Ministerial Order, which sets entry into force for October 1, 2026, triggering Phase 1 (large enterprises) from October 1, 2027 (12 months later) and Phase 2 (all others) from October 1, 2028 (24 months later).
Spain has now approved the Royal Decree (BOE-A-2026-7295) under the Crea y Crece Law, making B2B electronic invoicing mandatory for companies and professionals. This marks a major step toward reducing late payments, improving transparency in payment practices between businesses, and digitizing business transactions across the country.
New regulatory development: Ministerial Order draft published
Spain has published the draft Ministerial Order regulating the public electronic invoicing solution, marking a further step in the development of the Crea y Crece Law framework.
The draft foresees its entry into force on October 1, 2026, which marks the starting point for the 12-month and 24-month time limits for mandatory e-invoicing set out in Law 18/2022 and Royal Decree 238/2026. It will also define how the public invoicing platform operates within the broader e-invoicing ecosystem.
Once approved, this Ministerial Order will complete the regulatory framework and play a key role in the implementation of mandatory B2B electronic invoicing in Spain.
This article reflects the Royal Decree as published in the Official State Gazette (BOE-A-2026-7295). Certain technical specifications, particularly those relating to the public invoicing platform, will be further defined through a forthcoming Ministerial Order.
Latest key updates
Here are the most recent confirmed updates to Spain’s e-invoicing framework:
Ministerial Order draft published: The draft regulating the public invoicing platform has been released, with an expected entry into force on October 1, 2026.
12-month notice period confirmed: This expected entry into force on October 1, 2026, will trigger the implementation timelines established under Law 18/2022 and Royal Decree 238/2026, making B2B e-invoicing mandatory 12 months later for companies and professionals with an annual turnover exceeding €8 million (October 2027), and 24 months later for all remaining businesses (October 2028).
UBL replaces Facturae: UBL (Universal Business Language) will now be the required format for Spain’s public invoicing system, replacing Facturae.
Payment term clarifications: Clarifications have been provided regarding payment terms for credit and debit notes, including start and end dates.
AEAT publishes SPFE technical specifications: Following the AEAT developer workshop held on 19 May 2026, technical documentation for Spain's future public e-invoicing platform (SPFE) was published on 1 June 2026. The documentation provides the most detailed view to date of the platform's architecture, validation processes and invoice status reporting requirements, ahead of the publication of the final Ministerial Order.
On a somewhat related note, and addressing broader invoicing compliance, invoices created on the public platform will also be VERI*FACTU compliant. This requirement does not stem from the 'Create and Grow Law' but rather from the Anti-Fraud Law. (See below for further information about VERI*FACTU)
Create and Grow Law
The Royal Decree was approved on March 24, 2026, and published in the Official State Gazette (BOE-A-2026-7295). Implementation will follow a phased approach triggered by the publication of the forthcoming final Ministerial Order in the BOE:
12 months after entry into force of the Ministerial Order (expected October 1, 2026 – so applicable from October 1, 2027): Large businesses (turnover > €8M).
24 months after entry into force of the Ministerial Order (expected October 1, 2026 – so applicable from October 1, 2028): Large businesses (turnover < €8M).
10 essential facts about Spain's B2B e-invoicing law, “Create and Grow”
We have put together the top 10 points to help you understand Spain's law (Crea y Crece Law), from key dates to invoice formats and compliance requirements, based on the approved Royal Decree and current regulatory framework. These points reflect the Royal Decree as published in the Official State Gazette (BOE-A-2026-7295).
1. Date of entry into force
Implementation is phased following the publication of the Royal Decree, with further details to be defined by the forthcoming Ministerial Order:
(Expected October 1, 2027): Obligation for companies and professionals with a turnover above € 8 million.
(Expected October 1, 2028): Obligation for companies and professionals with a turnover below € 8 million.
The turnover period considered will be that of the year prior to the entry into force of the obligation.
2. Scope of the law
Who will the law affect, and which businesses are in scope?
Domestic.
B2B, private companies, and professionals.
Does not affect FACe (B2G).
Public companies and UTEs (Unión Transitoria de Empresas) are subject to the law in the same way as private companies.
3. Communication of mandatory invoice statuses
What updates to invoice statuses must be reported?
Mandatory statuses include the commercial acceptance or rejection of the invoice and its date, as well as the full effective payment and its date.
Businesses must notify these statuses within 4 calendar days from the date of the notification of the status.
This requirement aims to provide benefits such as reduced late payments, improved invoice tracking, and greater transparency in business relationships.
These status updates form a central part of Spain's strategy to improve payment transparency and reduce late payments. The public platform will use this information to provide greater visibility into payment behaviour throughout the invoice lifecycle.
By law, the maximum payment period is 60 days.
4. Signature
The rules concerning electronic signatures are as follows:
The invoice issuer must either sign the invoices, or:
They may choose to delegate the certificate to their e-invoicing service provider.
5. PDF
PDF invoices can fall into various categories, depending on a country’s invoice acceptance factors. Take a look at how the Spanish government will deal with PDF invoices within its B2B regulations.
Invoices in PDF format will continue to be accepted until the law becomes mandatory for businesses and professionals of all sizes.
Companies falling in the first wave of the obligation must issue invoices in electronic and PDF formats. They should be capable of receiving invoices in both formats.
Companies not in the first wave can keep their current invoice issuing methods until their obligation date, but they may issue electronically voluntarily.
6. Formats
It is vital to understand which electronic invoicing formats will be accepted within the regulations. A key change introduced in the regulation is the transition from Facturae to UBL (Universal Business Language), aligning Spain with the European Union standard EN 16931 and future initiatives such as VAT in the Digital Age (ViDA).
Public solution: UBL (Universal Business Language).
Private solutions: The billing platforms, solutions, or systems used by electronic invoice issuers will be required to send the true copy to the public electronic invoicing solution in UBL format. Other formats may be used for private exchanges, but UBL is mandatory for communication with the public platform.
7. Public platform
Many governments around the globe utilise a public/government platform within their B2G and B2B regulations.
Minimal solution for issuing invoices to suppliers and accessing customer invoices. Explicitly, it will not transmit the invoices, but only make them available for receivers. The platform will operate within a hybrid model, allowing businesses to exchange invoices either through accredited private service providers or directly through the public platform. In both cases, a faithful copy of the invoice must be made available to the tax authorities through the public infrastructure.
A copy of the invoice must be sent to the public platform, and the invoice statuses (acceptance and effective payment) must be communicated.
The detailed operation of this platform will be further defined in the forthcoming Ministerial Order.
8. SII (Suministro Inmediato de Información)
E-reporting to the SII will continue to work as before.
E-invoicing and e-reporting are two separate processes running in parallel.
9. Sanctions and control
No penalties regime is foreseen for the time being.
The State Observatory on Private Delinquency (Observatorio Estatal de la Morosidad Privada) will be responsible for monitoring the evolution of payment data and promoting good practices.
The publication of an annual list of non-compliant and late-paying companies (legal entities that fail to pay more than 5% of their invoices on time and whose total amount of unpaid invoices exceeds € 600,000) is envisaged.
10. International invoicing
There is no specific regulation at the international level, but at the European level, project ViDA (VAT in the Digital Age), which includes provisions for intra-Community e-invoicing and e-reporting requirements, is planned to take effect in July 2030.
Spain's ongoing e-invoicing developments are also aligned with the European Union's ViDA initiative, which aims to introduce harmonised digital reporting and e-invoicing requirements across Member States.
Learn more about ViDA via our blog post.
While these ten points cover the core of the upcoming B2B e-invoicing mandate, it's also crucial to understand two other related regulatory systems impacting invoicing in Spain: VERI*FACTU and TicketBAI.
What is VERI*FACTU?
VERI*FACTU, a Regulation governing the requirements for Billing Computer Systems (RRSIF), is a method for complying with Spanish legislation on computerised billing systems. It guarantees the integrity, conservation, accessibility, legibility, traceability and immutability of billing records.
Most businesses and self-employed professionals in Spain that are subject to Personal Income Tax or Corporate Income Tax will be required to use invoicing systems that comply with the technical requirements for both full and simplified invoices. Although the initial effective date was set for 1 January 2026, Royal Decree-law 15/2025 has extended the adaptation deadlines as follows:
Until 1 January 2027 for companies (taxpayers under Article 3.1.a).
Until 1 July 2027 for self-employed professionals and freelancers (the remaining taxpayers under Article 3.1).
Businesses already reporting through the Immediate Supply of Information (SII) system, as well as those benefiting from specific exemptions, are not required to apply these new rules.
Invoices generated via the public platform will automatically meet VERI*FACTU requirements, simplifying compliance for businesses.
What is TicketBAI?
TicketBAI, a system introduced by the Basque Country's Foral Tax Authorities, requires businesses to send and certify invoices for all economic activities. Developed in collaboration with the three Foral Treasuries and the Basque Government, TicketBAI establishes specific legal and technical obligations for billing software.
The system aims to control income from economic activities, particularly those involving transactions with final consumers. In order to adhere to TicketBAI regulations, which came into effect in regions such as Bizkaia on 1 January 2024, businesses must use compliant software such as Banqup. TicketBAI ensures the integrity and traceability of billing records by requiring specific data to be submitted to the tax authorities.
What businesses should do now
With the Royal Decree published and further regulatory development underway, businesses should start preparing for the transition to mandatory electronic invoicing:
Review current invoicing systems and processes,
Ensure readiness for UBL format,
Prepare to send and receive invoice status updates,
Evaluate technology providers to ensure compliance.
Taking early action will help businesses avoid disruption and ensure a smooth transition once the obligations come into force.
How Banqup can help
When choosing an electronic invoicing provider to help you navigate the various regulations and to help you become compliant, it can be difficult to understand what your business may need.
With Banqup, we guide you through all the changes, and we help future-proof your systems so that any regulation changes become our issue and not yours.
We already comply with the regulations in over 60 countries around the world. We tailor our products, and therefore your solution, so that it meets national and international regulations.
How else can we help you and other Spanish businesses?
We create value-added fields to the formats, specific to a sector or type of invoice: order/reference number, cost centers, etc.
We communicate mandatory statuses to the public platform, with the possibility of including additional statuses between private operators.
We provide additional statuses to the mandatory ones, for example, partial payments.
We automate the sending and reception of your invoices and invoice statuses.
We filter data for uploading and accounting in your ERP or financial systems.
We enable digital payments and reconciliations, making it even easier for your business to get paid more accurately and on time.
We provide receipt and data capture (OCR) for PDF invoices.
We supply advanced signature and electronic archiving.
We ensure your local and international compliance.
Start on your journey towards compliant electronic invoicing by discussing your business needs with a member of our Spanish team.
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