Electronic invoicing is already mandatory when you invoice a public administration, and has been since January 2015. Between businesses it is approved but has no start date yet, because the ministerial order that triggers its countdown has not been published. Verifactu, which is a different obligation, does have fixed dates: 1 January 2027 for companies and 1 July 2027 for the self-employed. Those are the three answers people are usually looking for.
If someone quotes you a specific day for business-to-business electronic invoicing, check where it comes from. The decree does not contain one.
An electronic invoice is a structured file that the recipient's system can read and process automatically. It carries the same legal content as a paper invoice and the same validity.
A PDF attached to an email is not an electronic invoice. It is a digital copy of a paper one. A person can read it; a system cannot process it without someone retyping the data. That difference is the whole point of the regulation.
In Spain the format used with the public sector is Facturae, an XML standard.
They stack. In time, most businesses will be under all three.
This is the part already in force, and the one people are surprised by.
Since 15 January 2015, under Ley 25/2013, public administrations have to receive invoices from their suppliers electronically. If you invoice a town hall, a regional government or a ministry, you send a Facturae file through their entry point, usually FACe, not a PDF by email.
The exception worth knowing: administrations may exclude invoices of up to €5,000 from the obligation. Many do, which is why some small suppliers have never had to deal with it. It is a choice each administration makes, so check with the one you invoice rather than assuming.
This is the obligation everyone is waiting for, and the one with the confusion.
It comes from Ley 18/2022, known as Crea y Crece, which made electronic invoicing compulsory between businesses and professionals in principle. A law of that kind needs implementing regulation to become operative, and that arrived as Royal Decree 238/2026, published in April 2026.
The decree sets a staged timetable:
Two transitional rules sit on top. During the first 12 months, larger businesses have to send a readable PDF alongside the electronic invoice unless the recipient accepts the original format. And reporting payment status stays voluntary for businesses under €8 million during their first 12 months.
The law itself is covered in more depth in the Crea y Crece law and electronic invoicing.
Because the countdown does not start with the decree. It starts with a ministerial order that has to approve the technical specifications and launch the public invoicing solution, and that order has not been published.
Until it appears, nobody can say when B2B electronic invoicing begins. The decree itself entered into force twenty days after publication, but its obligations are deferred to that order.
What this means in practice: the obligation is confirmed, the format is settled, and you have a minimum of two years from whenever the order appears if your turnover is under €8 million. What you cannot do is plan around a specific date, because there is not one to plan around.
Verifactu is a separate obligation and gets confused with this one constantly.
It does not govern the format you send. It governs the system you issue from: from your date, every invoice has to come out of certified software producing an unalterable record and a QR code.
1 January 2027 for companies. 1 July 2027 for the self-employed. Those dates are fixed and are not waiting on anything.
The two are compared in detail in the difference between Verifactu and electronic invoicing.
If you supply a public body: you are already obliged. Register with their entry point and issue in Facturae. Confirm whether they apply the €5,000 exclusion.
If you invoice other businesses: nothing is required yet, but the direction is settled. Choosing software that already handles structured electronic invoices means you will not have to migrate twice.
If you issue any invoice at all with software: get your vendor's Verifactu responsible declaration. This is the one with a real deadline, and holding non-compliant software carries a penalty.
Whoever you invoice: keep your numbering consecutive without gaps, and check you can export your history before you commit to any tool.
Article 201 bis of the Ley General Tributaria sets two, both classed as serious.
€50,000 per year for holding computer systems that do not meet the requirements, when they should be certified and are not, or when a certified system has been altered.
€150,000 per year for manufacturing, producing or marketing non-compliant systems, counted per financial year with sales and per distinct type of system.
The second falls on the software vendor. The first falls on you, which is why asking for the responsible declaration in writing is worth the five minutes.
Treating a PDF as an electronic invoice. It is not, and this is the single most common misunderstanding.
Mixing up the B2B obligation with Verifactu. Different laws, different dates, different things being regulated.
Believing a specific B2B date. There is not one yet.
Assuming it only applies above a turnover threshold. Turnover decides the order of the phases for B2B, not whether it applies. For Verifactu, turnover is irrelevant.
Waiting for an official list of approved software. There will not be one. Compliance works through the vendor's own responsible declaration.
Leaving it to your accountant. The obligation to issue through a valid system sits with you.
Public sector: already mandatory since January 2015, with a possible exclusion for invoices up to €5,000.
Business to business: approved, no date, at least 12 or 24 months from a ministerial order that has not been published.
Verifactu: 1 January 2027 for companies, 1 July 2027 for the self-employed, and those dates are firm.
The one thing to do this quarter: confirm your invoicing software has a published Verifactu responsible declaration, or change tool while there is no rush.
What it costs to get wrong: €50,000 a year for holding a non-compliant system.
For invoices to public administrations, yes, since January 2015. Between businesses, it is approved but has no start date yet. Verifactu, a separate obligation, applies from 2027.
As an invoice, yes, if it carries the required content. As an electronic invoice in the regulatory sense, no: that means a structured file a system can process.
Twelve months after the ministerial order for businesses above €8 million in turnover, and twenty-four months for everyone else. The order has not been published, so there is no date.
Facturae, submitted through the administration's entry point, usually FACe.
Administrations may exclude invoices of up to €5,000 from the obligation. Whether yours does is up to that administration, so ask.
Holding non-compliant systems carries a €50,000 penalty per year under article 201 bis of the Ley General Tributaria.
Related: Electronic invoicing for the self-employed / The Crea y Crece law / Verifactu vs electronic invoicing
