B2G e-invoicing (business to government) has been mandatory since 2015. B2B e-invoicing (business to business) becomes mandatory once the Ministerial Order under the Crea y Crece law is published. The second public consultation draft closed in April 2025. Once the Order is published, deadlines are counted from that date, not from the Royal Decree that preceded it.
This guide covers the B2B timeline, who must comply, the accepted formats, how the public platform works, the parallel Verifactu obligation, and what a compliance checklist looks like once the Order lands.
The Crea y Crece law (Ley 18/2022) made B2B e-invoicing mandatory for all businesses and self-employed professionals billing other businesses registered for tax. The law established the framework; the Ministerial Order sets the implementation dates.
Three things are required of every B2B e-invoice:
The authenticity and integrity of the invoice must be guaranteed. Advanced electronic signatures are expected, consistent with the rules already in place for B2G.
The clock starts from the Ministerial Order, not from any earlier regulatory text. As of mid-2026 the Order is still pending publication.
Once published, the phased timeline is:
If the Order is published in late 2026, the practical go-live windows become roughly 2027 for larger companies, 2028 for smaller businesses and autónomos, and 2029 for state reporting by smaller entities. These windows shift if the Order is delayed further.
The B2G obligation under Ley 25/2013 is already live and unaffected by the pending Order. Any invoice to a public administration must go through FACe (the national public entry point) in Facturae format.
The B2B obligation applies to:
B2C transactions (invoices to private consumers) are outside the scope of the mandatory B2B e-invoice. Businesses that sell exclusively to consumers are not required to issue structured e-invoices under this law, though Verifactu rules apply separately when they use invoicing software.
The Ministerial Order draft confirms four accepted syntaxes:
All formats must comply with the content requirements set by EN 16931, the EU norm that defines what mandatory and optional fields an e-invoice must carry.
The copy sent to the public e-invoicing platform must always be UBL. This applies even if the parties exchange invoices in Facturae or another format between themselves.
The Spanish government operates a public e-invoicing platform that serves two functions. First, it acts as the infrastructure for businesses that do not use a private operator. Second, it receives the mandatory UBL copia fiel from all transactions, regardless of which private platform the parties use.
Private e-invoicing operators (platforms, ERPs, accounting tools) must be interoperable with the public solution. Senders using a private platform still send the UBL copia fiel to the public platform automatically. Recipients can retrieve invoices through either channel.
The public platform also receives and stores state reporting data. When a recipient acknowledges, accepts, rejects, or confirms payment, those states flow back through the same infrastructure.
Autónomos who invoice other businesses will be required to issue and receive structured e-invoices within 24 months of the Order being published. The practical steps are:
Autónomos who invoice only private consumers are outside the B2B e-invoicing scope. However, Verifactu still applies to autónomos who use invoicing software, with a mandatory deadline of 1 July 2027.
For the full detail on the self-employed obligation, see mandatory electronic invoice for self-employed.
The two rules are complementary but solve different problems.
Verifactu governs the integrity of the invoicing software itself. It requires certified billing systems (SIFs) that chain every invoice record, prevent post-issue alteration, and add a QR code pointing to the AEAT verification page. Sending records to the AEAT in real time is optional (Verifactu mode) but the integrity controls are mandatory for anyone using invoicing software. The deadline is 1 July 2027 for companies and autónomos alike. For the full guide, see Verifactu.
The B2B e-invoice governs the format and exchange of the invoice document itself. It requires structured machine-readable formats, the UBL copia fiel to the public platform, and state reporting between trading partners.
How they interact: A single invoicing tool can cover both. Issue a structured invoice in UBL or Facturae (B2B e-invoice requirement), chain and sign it with your certified SIF (Verifactu requirement), and send the UBL copia fiel to the public platform. Choose software that handles both now rather than managing a migration later.
For a comprehensive overview of electronic invoicing rules, see the complete electronic invoice guide.
Once the Ministerial Order is published and your deadline window approaches:
The Crea y Crece law sets a maximum fine of €10,000 for businesses that are required to offer e-billing to their customers and fail to do so. Additional administrative and tax penalties may apply for failure to maintain compliant invoice records or for late state reporting once the obligation is active.
The penalty framework is separate from Verifactu penalties, which can reach €50,000 per year for businesses using non-certified billing software.
Is B2B e-invoicing already mandatory? Not yet for B2B. The Ministerial Order that activates the B2B deadlines is still pending as of mid-2026. B2G has been mandatory since 2015.
When will the Ministerial Order be published? The second public consultation draft closed in April 2025. No publication date has been confirmed. The working assumption for planning purposes is late 2026, which would make the first B2B deadline fall in late 2027.
Does the obligation apply to autónomos? Yes, for B2B invoicing. Autónomos have 24 months from Order publication to issue and receive structured e-invoices, plus one additional year to report states.
What format should I use? UBL is the most interoperable and cross-border-ready. Facturae is the existing Spanish standard and remains valid. The UBL copia fiel must be sent to the public platform regardless of which format you use with your trading partner.
What is the copia fiel? An exact copy of the invoice in UBL format that must be sent to the public e-invoicing platform. It serves as the government's canonical record of the transaction.
Do I need to comply if I only sell to consumers? No. The B2B e-invoice obligation applies only to transactions between businesses and professionals registered for tax. B2C sales are out of scope, though Verifactu applies if you use invoicing software.
What is the difference between Verifactu and the mandatory e-invoice? Verifactu regulates the integrity of the billing software (prevents tampering, adds QR, has fixed deadlines). The mandatory e-invoice regulates the format and exchange of the invoice document itself. Most businesses will need both.
renn's invoicing tool is built to be both Verifactu-compliant and B2B e-invoice-ready, covering UBL generation, the copia fiel requirement, and state reporting as the Ministerial Order activates deadlines. If you are setting up as an autónomo and want invoicing that covers both obligations from day one, renn handles autónomo registration online and the invoicing compliance from there.
