Electronic invoicing with the public sector has been mandatory since 2015 via FACe. For business-to-business transactions, it becomes mandatory in phases once the implementing regulation under the Crea y Crece law is published. This guide explains what an electronic invoice is, when B2B becomes mandatory, how it differs from Verifactu, and what to do now.
What is an electronic invoice? A tax invoice in structured digital form that proves who sent it, shows it has not been altered, and can be processed automatically by the recipient's system. It has the same legal fields as a paper invoice but is issued, transmitted, received, and archived digitally.
Is e-invoicing mandatory now? For public-sector clients (B2G), yes: mandatory since January 2015 via FACe in Facturae format. For B2B, mandatory once the implementing ministerial order under Crea y Crece is published. As of mid-2026 the order is pending.
What are the B2B deadlines? Companies above €8 million turnover: one year from publication of the ministerial order. All other businesses and autónomos: two years from publication. Plan for rollouts during 2027.
Is electronic invoicing the same as Verifactu? No. Electronic invoicing defines the document format and the network used to exchange it. Verifactu (RD 1007/2023) is a separate requirement for the invoicing software itself: it mandates hash-chained records, QR codes, and optionally real-time transmission to the AEAT. Verifactu applies from 1 July 2027 to all businesses using invoicing software.
What format is required? For B2G: Facturae 3.2.1 or 3.2.2, signed with a qualified certificate, delivered via FACe. For B2B: the final regulation will define formats, but Facturae and UBL-compatible standards are expected.
An electronic invoice has the same mandatory fields as a paper invoice: invoice number and series, issuer and recipient names and NIFs, issue date, description of goods or services, tax base per line, VAT rate and amount, any IRPF withholding, and the total payable. The difference is how it is created, transmitted, acknowledged, and stored.
Three legal qualities must be guaranteed for an electronic invoice to be valid:
A simple PDF sent by email is not an electronic invoice in the legal sense unless it carries a qualified electronic signature. An XML file in Facturae format, signed and delivered via FACe or FACeB2B, is a valid electronic invoice. For the full definition, see what is an electronic invoice in Spain.
For B2G billing today:
Facturae format (version 3.2.1 or 3.2.2) is required for all invoices to public administrations. You must sign the file with a recognised qualified certificate (DNIe, a certificate from FNMT, or an equivalent accredited authority). Delivery is via FACe (the central government portal) or a regional equivalent. FACeB2B is the interoperability point for B2B. After submitting, you track the invoice status in the portal: received, registered, approved, or rejected.
Tools that generate and submit Facturae: B2Brouter (free basic tier), renn, Holded, Quipu, and FacturaDirecta. For a full walkthrough of invoicing as a self-employed professional, see the autónomo invoicing complete guide and electronic invoicing for the self-employed.
For B2B once the regulation is published:
The regulation will define the required formats (Facturae and UBL-compatible standards are expected), how public and private platforms must interconnect, the acknowledgement messages that must be exchanged, and payment status reporting. Your invoicing software will need to issue, receive, acknowledge, report status, and archive automatically. Start with software that already supports Facturae; the step to full B2B compliance will be smaller.
Key terms you will see:
B2G: already mandatory. If you invoice any ministry, regional government, council, hospital, university, or other public body, you must use Facturae and submit via FACe. A paper invoice or a simple PDF is not valid and will not be processed.
B2B: phased rollout after the ministerial order. The Crea y Crece law (Ley 18/2022) mandates structured B2B e-invoicing for all businesses. The implementing ministerial order defines the technical requirements and start dates. Once published:
The government completed a public consultation in 2026. Final approval is pending. Plan for rollouts during 2027. For the full rules and dates, see mandatory electronic invoice in Spain.
Verifactu: separate deadline, 1 July 2027. From 1 July 2027, all businesses and autónomos using invoicing software must use a certified system (SIF) under RD 1007/2023. Each invoice must carry a QR code and a hash-chained record. This applies whether or not B2B e-invoicing is mandatory for your business yet. Fines for non-compliant software reach up to €50,000 per year.
Sanctions under Crea y Crece: draft texts include fines for businesses that refuse to receive e-invoices or deny access to invoice records for former customers. Treat specific figures as indicative until the final regulation is published.
Ley 18/2022 (Crea y Crece) was designed to cut late payments, improve invoice traceability across the economy, and accelerate digital adoption among SMEs.
Why e-invoicing reduces late payments: structured electronic invoices create a timestamped trail from issue to receipt to acknowledgement to payment. The regulation is expected to require recipients to report invoice status and, in many cases, the payment date. This makes non-payment visible and creates a basis for enforcement.
What it means for your workflow: once your phase begins, every invoice you issue to another business must be a structured electronic invoice. You must also be capable of receiving and acknowledging electronic invoices from your suppliers. A system that only issues is not compliant.
What stays the same: Facturae remains the standard for B2G. Your public-sector billing workflow does not change. For B2B, the regulation will require interoperability between platforms so that invoices issued on one system can be received on another. For the full breakdown of what Crea y Crece requires, see Crea y Crece law: B2B e-invoicing rules and deadlines.
Every business and professional must issue an invoice for all commercial transactions. This obligation comes from the Billing Regulation (RD 1619/2012).
Full invoice (factura completa): required for all B2B transactions where the recipient needs to deduct input VAT, for transactions above €400 where the buyer requests one, and for all professional services with IRPF withholding.
Simplified invoice (factura simplificada): allowed for transactions under €400 where the buyer is a private individual and does not need VAT deduction, and for specific retail activities authorised by the AEAT. Between businesses, the recipient normally needs a full invoice to deduct VAT.
Rectificativas: if an invoice contains an error or must be cancelled, issue a rectificativa (credit note). It must reference the original invoice number and series. Keep both the original and the rectificativa in your archive.
Retention: all invoices must be kept for a minimum of four years and be accessible on request during any AEAT inspection. For the full list of required fields on every invoice, see mandatory invoice details.
B2G today (step by step):
B2B once the regulation is published:
Your software will need to connect to FACeB2B or a certified private platform, issue the structured invoice, receive an acknowledgement from the recipient, and log the payment status when confirmed. Manual steps will be minimal if you choose software that handles the full cycle.
Acceptance and rejection: when you receive an electronic invoice from a supplier, you must acknowledge receipt. You can accept, reject, or request a correction. Rejection must be documented; you cannot simply ignore an invoice. Your software should manage the acknowledgement queue automatically.
Archiving: store the original XML file, the electronic signature, and any acknowledgement messages. A PDF printout alone is not sufficient for audit purposes. Many platforms archive automatically and provide export on request. For step-by-step instructions on creating and sending an invoice, see how to make a self-employed invoice.
Sending a PDF and calling it an electronic invoice: a PDF without a qualified electronic signature is a paper invoice in digital form. It does not meet the B2G requirement and will not meet the B2B requirement.
Using a free certificate from a non-accredited issuer: only qualified certificates from accredited trust service providers are valid for signing Facturae. The FNMT certificate is the most common for autónomos and SMEs.
Not tracking FACe status: submitting to FACe does not guarantee acceptance. Check the portal regularly; a rejected invoice means you have not been paid a legal invoice and the public body is not obliged to process it until a valid version is submitted.
Ignoring Verifactu as “a B2B thing”: Verifactu (1 July 2027) is independent of B2B e-invoicing. It applies to your invoicing software regardless of whether you bill businesses, individuals, or public bodies.
Not being able to receive e-invoices: once Crea y Crece applies to your phase, you must accept electronic invoices from suppliers, not just issue them. Software that only issues will leave you non-compliant on the receiving side.
Deleting XMLs after printing PDFs: the original signed XML and the acknowledgement messages are the legally valid record. Keep them for four years minimum.
