Spain E-invoicing Mandate: Requirements, Timeline, Format & Penalties

Spain e-invoicing mandate introduces domestic B2B e-invoicing in phases with a hybrid model. The Royal Decree 238/2026 defines Crea y Crece, mandatory exchange of B2B e-invoices. The businesses must use structured e-invoices, interoperable platforms and new data-sharing requirements for domestic B2B transactions.

The new Ministerial Order HAC/1028/2026 entered into force on 6 Oct 2026 starts the countdown to mandatory B2B e-invoicing. It provides the technical and functional specifications for Crea y Crece Law and Royal Decree 238/2026.

Key Takeaways

• Phase 1 of the Spain B2B e-invoicing mandate starts in October 2027 for businesses with annual turnover exceeding €8 million. The remaining businesses follow phase 2 in Oct. 2028.
• Royal Decree 238/2026 lays out the B2B framework, but a separate Ministerial Order sets the final dates.
• SII in Spain has been in force since July 1, 2017 for VAT records reporting.
• Eligible taxpayers must send their VAT bill details to SII within four days of issuance or receipt of the actual bills.
• VeriFactu kicks in on 1 January 2027 for corporate taxpayers, and applies to self-employed from 1 July 2027.

What is the B2B e-Invoicing Mandate in Spain?

Under the e-invoicing mandate in Spain, businesses have to send structured invoices while simultaneously reporting a parallel copy to the tax authority, a hybrid model unlike anywhere else in Europe.

The VAT ledger reporting to AEAT has already been in force since 2017. The new layer of e-invoicing mandate, Crea y Crece, necessitates the use of electronic invoices as the only valid format for B2B, self-employed, and B2G transactions. An electronic invoice is an invoice issued, transmitted and received electronically. Under the B2B mandate, it must be an automated and structured electronic message.

Spain's B2B e-invoicing mandate originates from: 

• Ley 56/2007, Article 2 bis;
• Ley 18/2022, de creación y crecimiento de empresas, Article 12;
• Real Decreto 238/2026, which establishes the detailed operating framework;
• The new Ministerial Order HAC/1028/2026 effective from 6 Oct 2026 starts the countdown to mandatory e-invoicing.
• Ministerial order regulates the practical application of Real Decreto 238/2026 with technical and functional specifications.

Ley 18/2022, the Crea y Crece Law, passed in September 2022. Article 12 of that law requires businesses and self-employed professionals established in Spain to issue and receive structured electronic invoices in their B2B transactions.

When Will E-invoicing in Spain Become Mandatory?

The mandatory deadlines for the B2B e-invoicing in Spain will phase in 12 and 24 months from the date the new Ministerial Order came into force on 6 October 2027. Following are the phases for e-invoicing to go live:

• Businesses with annual turnover above €8 million: 12 months from the entry-into-force date (October 2027)
• All other businesses and professionals within scope: 24 months from the entry-into-force date (October 2028)

AEAT also specifies details on the role of private platforms, invoice e-reporting and payment-status reporting.

Spain E-Invoicing Timeline: Key Dates and Deadlines

Let’s look at the expected timeline for the e-invoicing implementation in Spain:

Spain E-Invoicing Framework: SII, VeriFactu and Crea y Crece

AEAT is reconditioning the B2B invoice transactions and tax reporting landscape with a unique hybrid approach of private platforms and public reporting. It’s also a big step towards the wider digital VAT compliance under EU-ViDA by 2030.

Three overlapping regime and other requirements of Spain E-invoicing

Spain has three separate digital regimes (SII, SIF/VERI*FACTU, Crea y Crece) running parallely at once, and it's common for everyone to conflate them:

SII (Suministro Inmediato de Información) 

SII in Spain has been live since July 2017.  The Suministro Inmediato de Información is the electronic maintenance of IVA ledgers. AEAT requires large taxpayers, VAT groups and businesses under the REDEME scheme to report their transaction level VAT ledger data in near real-time. It's a VAT reporting obligation, and not an invoice format requirement.

VeriFactu in Spain

Established by Royal Decree 1007/2023 and updated by Royal Decree-Law 15/2025, it’s primarily a software integrity rule within the business. It requires billing systems within the businesses to generate tamper-proof, sequentially chained invoice records with a digital fingerprint and QR code. Businesses already under SII are exempt from Verifactu, since SII already gives the tax authority continuous visibility into their invoices.

Crea y Crece Law in Spain

It’s the B2B e-invoice exchange rule established by Law 18/2022, and developed by Royal Decree 238/2026. It governs how structured invoices are exchanged by the businesses and requires reporting of invoice status, acceptance, rejection and payment.

Each of these systems have their one deadline and any single business can be subject to all of them simultaneously. The e-invoicing mandate in Spain has multiple requirements as per its territories and business forms, not only one single obligation. You must distinguish between the national B2B exchange mandate, B2G invoicing, and the foral systems operating in the Basque Country and Navarra.

VeriFactu vs Crea y Crece: What's the Difference?

A single business can be subject to both at once. VeriFactu controls how your software writes the invoice. Crea y Crece controls how you send it.

Spain B2G E-Invoice Format

Business-to-government electronic invoicing means invoicing a Spanish public administration. Since 2015, B2G e-invoicing in Spain has been mandatory for transactions with Public Administrations. It is a separate, already-operational regime governed principally by:

• Ley 25/2013, de impulso de la factura electrónica;
• the public administration’s designated general entry point;
• FACe, where used by the relevant administration;
• the Facturae structured XML format and applicable signature requirements.

B2G exclusions

Public bodies can, through their own regulations, exclude:

• Invoices up to €5,000; and
• Invoices issued to services located abroad.

The €5,000 threshold is therefore not a universal exemption for every Spanish public body. The supplier must check the rule adopted by the particular administration. The central FACe framework includes such an exclusion for qualifying invoices.

TicketBAI, Batuz and NaTicket

The TicketBAI is the mandatory tax e-Reporting framework in the Basque Country. Its purpose is to prevent tax evasion in the designated territories through authenticated e-invoicing.

• TicketBAI: a Basque foral invoicing-control system requiring compliant invoicing software, a signed XML file for the transaction, invoice chaining, a TicketBAI identifier and a QR code.
• Batuz: Bizkaia’s broader compliance framework, consisting principally of TicketBAI, the electronic Libro Registro de Operaciones Económicas - LROE, and tax-return assistance or drafts.
• NaTicket: Navarra’s planned immediate or near-immediate invoice-record reporting system. It remains a development project rather than a fully confirmed mandatory regime.

Spain E-Invoicing: Technical and Functional Requirements

Wonder how e-invoicing works in Spain? Let’s dig deeper. Once the e-invoicing mandate in Spain gets implemented here is how it’s going to work:

Invoice generation & Issuance Requirements

B2B businesses will have to follow these technical requirements:

• Generate a structured electronic invoice and use one of the permitted syntaxes;
• Transmit it through a qualifying e-invoicing solution provider, or the AEAT public solution, or a combination of the two;
• Include the prescribed unique invoice identification;
• Sign invoices exchanged through a private platform with an advanced electronic signature;
• Preserve authenticity of origin, integrity and traceability;
• Make its private invoice-receipt point public, where it has chosen one.

Copy of E-Invoice to the Public Solution

If a business issues the invoices through a private platform rather than the public solution, the same system must simultaneously send a copia electrónica field to the public solution in UBL syntax.

It is the structured copy made available to the public system for interoperability, payment monitoring and administration purposes.

E-Invoice Status Reporting Requirements in Spain

The invoice recipient must communicate at least:

• Commercial acceptance or rejection and the relevant date;
• Full effective payment and the payment date.
• Partial acceptance, partial payment, assignment to a third party, the date goods or services were received and similar events may be communicated where supported.

In the absence of a communicated rejection or discrepancy, the regulation provides for a presumption of acceptance.

SIF/VERI*FACTU Requirements in Spain

VeriFactu is a software program within the organization to ensure secure and transparent submission of e-invoices to the AEAT. A business covered under VeriFactu/SIF must do following things to enable effective tax supervision:

• Generate a record when an invoice is issued;
• Generate an annulment record where required;
• Use a digital fingerprint or hash chain record;
• connect each record with the preceding record;
• prevent concealed alteration or deletion;
• maintain event and traceability controls;
• support electronic transmission to AEAT;
• include a tax QR code on invoices or tickets;
• include the prescribed VERI*FACTU wording where records are actually transmitted through that mode.

For structured electronic invoices, Orden HAC/1177/2024 permits the underlying URL to be included as an independent field instead of displaying the QR image itself.

TicketBAI Requirements in the Basque Country

Each of the three Basque territories operates its own reception, validation, correction and enforcement arrangements.

The process normally requires:

• Generation of one TicketBAI XML file for the transaction;
• Chaining with the preceding invoice;
• Electronic signature of the XML;
• Transmission to the competent Hacienda Foral;
• Inclusion of the TicketBAI identifier and QR code on the customer-facing invoice;
• Separate correction or annulment procedures rather than deletion of the original record.

E-Invoice Formats Accepted in Spain: UBL, CII and EDIFACT

The invoices for B2B transactions must comply with the EN 16931 semantic data model. The UBL is applied under the European EN 16931 standard and the PEPPOL network. The accepted invoice formats and transmission for B2B are as follows:

• UBL: Universal Business Language;
• CII: UN/CEFACT Cross Industry Invoice, European XML standard;
• EDIFACT invoice messages;

Private e-invoicing solution platforms must be able to transform between supported formats without hampering their authenticity and integrity. Such invoices transmitted through private exchange platforms must carry an advanced electronic signature.

Spain B2G E-Invoice Format

For B2G invoice format, Ley 25/2013 established the followings:

• Facturae version 3.2 as the statutory baseline structured format. It’s the mandatory electronic format for submission to Public Administrations.
• Facturae is a structured XML format containing required fields and enables automated processing.
• XAdES electronic signature;
• Public administration’s entry point is FACe for Facturae invoices submission.

FACe routing also requires the correct administrative destination, normally represented through the relevant DIR3 accounting office, managing body and processing unit codes.

TicketBAI Invoice Format and Requirements

TicketBAI uses a territory-specific TicketBAI XML/XSD implementation. It must have electronic signature, including XAdES requirements, invoice chaining information, TicketBAI identifier, QR code, and registration, annulment and correction messages.

LROE electronic ledger complements the rollout of TicketBAI. Besides TicketBAI requirements, businesses must submit records of VAT, corporate tax, and personal income tax returns. 

Spain E-Invoicing Scope: Who Is Included and Excluded?

The obligation of e-invoicing mandate covers all businesses and professionals (empresarios y profesionales) subject to the exclusions mentioned in regulations under Royal Decree 1619/2012.

B2B E-Invoicing: Who Is Covered in Spain?

It encapsulates domestic B2B transactions between Spanish-established entities. Under Article 3 of Real Decreto 238/2026, the obligation applies where:

• The supplier is required to issue an invoice under the Spanish invoicing regulations; and
• The recipient is an empresario or profesional with its place of business in Spain, or a permanent establishment in Spain, or failing those, its domicile or habitual residence in Spain; and
• The transaction is directed to that Spanish establishment, permanent establishment, domicile or residence.

The rule also applies where the customer or a third party physically prepares the invoice on behalf of the supplier.

B2B E-Invoicing Exclusions in Spain

Real Decreto 238/2026 excludes:

• Transactions with private consumers (B2C)
• Transactions documented through ordinary facturas simplificadas under Article 4 of Real Decreto 1619/2012; but not qualifying simplified invoices under Article 7.2 of that regulation;
• Specified activities of the regulated electricity and organised gas-market operators;
• IATA-regulated payment clearing and settlement arrangements;
• If any additional sector is temporarily or definitively excluded by the Ministry of Economy with a future ministerial order.

Spain E-Invoicing Non-Compliance: Penalties and Consequences

Non-compliance with the B2B e-invoicing mandate attracts potential administrative penalties once it’s into force. The non-compliance will probably include, 

• Issuance of non-compliant e-invoices
• No e-reporting or submission
• Non-compliant e-invoicing platforms
• Insufficient invoice traceability

Penalties for Non-Compliance with B2B e-invoice Mandate

Beyond penalties, non-compliance also creates commercial friction, exclusion from supply chains that already require e-invoicing, and potential liability for software providers whose systems.

Spain E-Invoicing Mandate: Key Details at a Glance

How ClearTax Can Help with e-Invoicing in Spain

As the Crea y Crece rollout for B2B e-invoicing takes effect from 2027, this means acceptance, rejection and payment status can be tracked in the same workflow your tax and finance teams already use for SII, rather than as a parallel system built from scratch. 

Managing SII and the incoming Crea y Crece B2B e-invoicing mandate as two separate projects is how most groups end up duplicating the same work. It may include mapping customer and supplier data once for real-time VAT reporting and again for structured B2B exchange. 

ClearTax offers a single compliance layer that sits between your ERP and both destinations. Invoice data is mapped once, validated against the applicable rules, and routed to SII for VAT ledger reporting and to the relevant Crea y Crece channel, whether that's a private platform or the public SPFE, for B2B exchange and status tracking.