E-Invoicing in Spain 2026 – Crea y Crece Mandate, Timeline and Requirements

Spain is implementing one of the most comprehensive B2B e-invoicing mandates in Europe. After years of legislative development, the regulatory framework is now largely in place — with mandatory compliance for large companies expected from October 2027. Here is what businesses need to know.

Background: B2G is Already Live

Electronic invoicing for transactions with public entities (B2G) has been mandatory in Spain since 2015 via the FACe platform, for invoices exceeding €5,000. The reform now extends mandatory e-invoicing to domestic B2B transactions under Law 18/2022 (Ley Crea y Crece — Create and Grow Law).

Current Status and Timeline (2026)

On 24 March 2026, Spain’s Council of Ministers adopted Royal Decree 238/2026, establishing the legal architecture for mandatory B2B e-invoicing. A draft Ministerial Order, released for public consultation in April 2026, defines the technical specifications of the public platform and sets 1 October 2026 as the date from which compliance deadlines begin counting.

The phased rollout timeline is:

• 1 October 2027 — Large companies with annual turnover exceeding €8 million must comply (12 months after the Ministerial Order entry into force)
• 1 October 2028 — All other in-scope businesses and self-employed professionals (24 months after entry)

These dates remain subject to the final publication of the Ministerial Order, and could still shift.

Who Is Affected?

The Crea y Crece B2B e-invoicing obligation applies to domestic B2B transactions between companies and professionals established in Spain. Key exclusions:

• International transactions where one party is not established in Spain (no permanent establishment) are excluded
• B2C transactions are excluded
• Simplified invoices and transactions not requiring an invoice are exempt
• Non-resident companies are only subject to the obligation if their local B2B transactions are carried out through a permanent establishment in Spain for indirect tax purposes

Two Parallel Obligations: Crea y Crece vs. VeriFactu

Spain has introduced two distinct but complementary e-invoicing obligations that businesses must not confuse:

Crea y Crece (Royal Decree 238/2026) — governs the format, transmission, and exchange of B2B invoices between trading partners, plus mandatory invoice status reporting. This is the B2B e-invoicing mandate.

VeriFactu (Royal Decree 1007/2023) — requires certified billing software that produces tamper-proof, sequentially chained invoice records with a digital fingerprint, QR code, and timestamp. Current VeriFactu deadlines are 1 January 2027 for corporate taxpayers and 1 July 2027 for self-employed persons. Businesses already under the SII real-time reporting system are exempt from VeriFactu.

A single business may be subject to both simultaneously.

The E-Invoicing System Architecture

Spain has opted for a decentralised Continuous Transaction Controls (CTC) model with a hybrid architecture:

Public electronic invoicing solution (managed by AEAT, the Spanish Tax Administration) — serves as a mandatory universal repository for all issued and received e-invoices, an optional issuance platform particularly aimed at SMEs, and a payment monitoring tool tracking settlement and late payment behaviour.

Private e-invoicing exchange platforms — operated by approved agents. Companies using private platforms must send a copy of each invoice to the public platform. Platforms must connect to any other platform within one month of receiving a request from a client, ensuring interoperability.

Invoice status reporting — recipients must inform issuers of invoice status (received, accepted, rejected, payment date) on an ongoing basis. This information must be forwarded to AEAT within four calendar days.

Accepted E-Invoice Formats

Spain’s system supports the following e-invoice formats:

• UBL (ISO/IEC 19845:2015) — now the primary required format; a copy in UBL (“copia fiel”) must be sent to the public platform
• Facturae — national XML standard, also used in B2G
• CII (CEFACT/ONU)
• EDIFACT (ISO 9735)

All formats must comply with the EN 16931 European standard.

E-Invoice Integrity and Authenticity

E-invoices must be signed with an advanced electronic signature. Each invoice must also carry a unique QR code containing the issuer’s tax identification number, invoice number, issuance date, and invoice series — enabling quick verification of document authenticity.

Archiving

E-invoices must be stored for at least 6 years. They may be stored abroad, provided specific security and accessibility requirements are met — archived invoices must be available upon request from tax authorities and stored in a way that guarantees their integrity and authenticity.

Preparing for Compliance

For e-commerce businesses and companies operating in Spain, the key steps are:

• Select appropriate software — ensure systems can generate invoices in UBL format and comply with both Crea y Crece and VeriFactu requirements
• Monitor the Ministerial Order — the final publication will confirm the exact October 2026 entry-into-force date and trigger the compliance countdown
• Understand your category — businesses over €8M turnover face the October 2027 deadline; others have until October 2028
• Integrate with platforms — decide whether to use the public AEAT platform or a private approved provider, and establish connections ahead of the mandatory dates
• Train staff — invoicing, accounting, and IT teams need to understand both the B2B exchange process and the status reporting obligations

Summary

Spain’s mandatory B2B e-invoicing mandate under Ley Crea y Crece is now legally established following the adoption of Royal Decree 238/2026 in March 2026. The compliance countdown begins when the Ministerial Order takes effect (expected October 2026), with large companies going live in October 2027 and all others in October 2028. Businesses should also prepare for VeriFactu certified software requirements, which have separate but related deadlines in 2027.

For questions about e-invoicing compliance in Spain or other EU countries, our team is ready to assist: Contact us — amavat®