When does mandatory B2B e-invoicing apply to me?

Regulation approved, clock stopped.

Dates, thresholds and penalties last verified: 24 July 2026, against the BOE and the AEAT (sources at the end).

Mandatory e-invoicing between businesses stems from Article 12 of Law 18/2022 on the creation and growth of companies — Spain’s ‘Create and Grow’ Act —, which amends Article 2 bis of Law 56/2007 and extends the obligation to issue and send electronic invoices to all businesses and professionals in their commercial relationships (B2B transactions). Under its implementing regulation, it covers those who issue invoices to other businesses or professionals with their place of business, permanent establishment or residence in Spain; excluded, among others, are transactions documented in simplified invoices, certain transactions by electricity and gas market operators, and IATA clearing houses. Its purpose is not tax collection but commercial transparency: making real payment terms visible and curbing late payment.

Here comes the fact half the internet gets wrong. The implementing regulation already exists: it is Royal Decree 238/2026, of 25 March, published in the BOE on 31 March 2026 (BOE-A-2026-7295) and in force since 20 April 2026. But the 12- and 24-month periods do not run from the regulation: its third final provision anchors them to the entry into force of the ministerial order governing the public e-invoicing solution — and that order, as of 24 July 2026, has not yet been published in the BOE. The Ministry of Finance opened the draft to public consultation on 16 April 2026 and the text itself foresees its entry into force on 1 October 2026, which would place the deadlines around October 2027 and October 2028. These are estimates: any website giving you an exact day today is extrapolating, not quoting the BOE.

Who, when and with what nuances

The phase split is simple: those whose turnover exceeded 8 million euros in the previous year will have 12 months from the ministerial order; everyone else — the vast majority of SMEs and all self-employed workers — will have 24 months. Beyond the format, the rules require reporting invoice statuses (commercial acceptance or rejection and full effective payment) within a maximum of 4 calendar days, excluding Saturdays, Sundays and national public holidays. There is a grace period designed for the smallest players: for natural persons and entities under the income attribution regime invoicing 8 million euros or less, reporting those statuses will be voluntary during their first 12 months of obligation and mandatory afterwards. Private exchange platforms also have their own transitional periods (24 months) to meet the interconnection and interoperability requirements.

What non-compliance can cost you

The penalty regime is not in the regulation — Royal Decree 238/2026 does not add one of its own — but in Law 56/2007 (Art. 2 bis, paragraph 9), as worded by Law 18/2022: a warning or a fine of up to 10,000 euros, for conduct such as not offering recipients the option of receiving electronic invoices or not allowing former clients access to their invoices. The sanctioning body is Spain’s Secretariat of State for Digitalisation and Artificial Intelligence.

B2B e-invoicing and Verifactu: two separate, cumulative obligations

Sharing the word “invoice” does not make them the same rule. Verifactu (Royal Decree 1007/2023, with its enforceability postponed by Royal Decree-Law 15/2025) regulates the requirements of invoicing software — tamper-proof records, hash fingerprint, submission to the AEAT — and already has firm dates: 1 January 2027 for Corporate Income Tax payers and 1 July 2027 for everyone else, with fines of up to 50,000 euros per financial year for using or holding non-compliant software (Art. 201 bis of the Spanish General Tax Law). B2B e-invoicing regulates the format and exchange of invoices between businesses and its countdown has not yet formally started. Most businesses will have to comply with both — and Verifactu arrives first. To see them side by side, use the Verifactu vs B2B e-invoicing comparison tool; and for your exact Verifactu date, the Verifactu deadline calculator.

The public solution: comply for free

Royal Decree 238/2026 designs a mixed system: private exchange platforms and a public e-invoicing solution managed by the AEAT, free to use, which also acts as a universal invoice repository (private platforms must send it a copy). The common format is the EN 16931 semantic model, with four accepted syntaxes: Facturae, UBL, CII (UN/CEFACT XML) and EDIFACT; private platforms must be able to convert between all of them and the public solution operates in UBL. The final technical details — authentication, unique invoice code, communication between platforms — will be set by the pending ministerial order. All of this is part of our digitalisation practice, where we also cover the Kit Digital programme and AI adoption in SMEs.