In Spain, e-invoicing is already mandatory in B2G (business to government) since 2015. B2B (business to business) will start once the Crea y Crece regulation is approved by a Ministerial Order (the formal rule that activates deadlines). The latest draft confirms accepted formats - UBL, CII, EDIFACT, Facturae - the public e-invoicing solution (the government platform), the required UBL "copia fiel" (an exact copy in UBL sent to the public platform), and how and when recipients must report invoice "states" (received, accepted, rejected, paid). From approval, companies with over €8M turnover get 12 months. The rest get 24 months, with one extra year for small firms and sole traders to report states. In parallel, Verifactu (anti-fraud rules for billing software) makes certified billing systems compulsory in 2026.
FAQ
When does the electronic invoice come into effect?
From the Ministerial Order approval: over €8M in 12 months, €8M or less in 24 months, and state reporting for smaller firms in 36 months.
Is the mandatory electronic invoice already active in 2025?
No. 2025 is the regulatory year. The second draft closed in April. The Order is still pending.
Mandatory electronic invoice for self-employed individuals?
Yes, for B2B only. Two years to issue and receive e-invoices, plus one extra year to report states. Verifactu applies on 1 Jul 2026.
Electronic invoice formats?
UBL, CII, EDIFACT, and Facturae. The copy sent to the public solution must be UBL.
AEAT’s role?
AEAT (the Spanish Tax Agency) operates the public e-invoicing solution and Verifactu. It sets the state-reporting rules and controls.
Mandatory electronic invoice: the short answer
B2G is already mandatory. B2B starts after the Ministerial Order. Verifactu has fixed dates in 2026.
- Today, B2G e-invoicing is mandatory via FACe (the public entry point) using Facturae (Spain’s XML format for public-sector invoices).
- Next for B2B: after approval, firms over €8M comply in 12 months. Others in 24 months. Smaller firms get up to 36 months to report states.
- Formats: UBL, CII, EDIFACT, and Facturae. The UBL "copia fiel" goes to the public solution.
- Verifactu is separate but complementary. Certified billing systems are mandatory on 1 Jan 2026 for companies and on 1 Jul 2026 for sole traders.
When is electronic invoicing mandatory?
B2G is live since 2015. B2B will be phased by company size once the Order is approved.
- B2G: suppliers send e-invoices via FACe. Facturae is required.
- B2B: the clock starts with the Ministerial Order, not the Royal Decree (the broader regulation text). Timelines: 12 months for over €8M and 24 months for €8M or less.
- State reporting: recipients must acknowledge, accept or reject, and later confirm payment, sending each state within 4 calendar days.
- If the Order lands in late 2025, likely go-live windows are: 2026 for over €8M, 2027 for €8M or less, and 2028 for state reporting by smaller firms.
Entry into force and approval path in 2025
The second hearing closed in April 2025. The Ministerial Order will trigger the deadlines.
The 2025 draft clarifies the UBL "copia fiel," recipient state reporting, and alignment with EN 16931 (EU e-invoice content rules).
It also clarifies how to calculate payment terms and how to record rejection and payment states. Interoperability rules are tighter than in 2024.
Deadlines start counting from the Ministerial Order.
Mandatory electronic invoice for self-employed individuals
If you invoice other businesses, you will e-invoice. B2C (billing consumers) is out of scope.
- Scope: B2B only.
- Timing: two years from the Order to issue and receive B2B e-invoices, plus one extra year to report states.
- Options: use a compliant private platform or the public e-invoicing solution. In all cases, send the UBL "copia fiel" to the public solution.
- Parallel rule: Verifactu for autónomos starts on 1 Jul 2026. Many tools will support both B2B e-invoicing and Verifactu.
See more about electronic invoicing for self-employed here.
Electronic invoice law: what the laws say
Three key rules today:
- Ley 25/2013: sets B2G e-invoicing and the FACe entry point.
- Ley 18/2022 (Crea y Crece): makes B2B e-invoicing mandatory and gives users e-billing rights, with fines up to €10,000 if you must offer e-billing and do not.
- Royal Decree project + Ministerial Order: define formats, transport, interoperability, and state reporting.
For a complete walkthrough click here.
Electronic invoice formats, signature and storage
- Formats: UBL, CII (UN/CEFACT Cross Industry Invoice), EDIFACT (classic EDI), and Facturae.
- Standard: EN 16931 is the EU model for what an e-invoice must contain. Peppol BIS (the common profile used on the Peppol network) fits under UBL if it follows EN 16931.
- Copy to public solution: must be UBL to keep ingestion uniform.
- Authenticity and integrity: must be guaranteed. Advanced electronic signatures (a digital certificate that proves who sent it and that it was not altered) are expected in B2B, as in B2G.
- Storage: keep e-invoices for at least 4 years for tax purposes. Some sectors or B2G may require longer.
AEAT, Verifactu and the "mandatory electronic invoice AEAT" idea
Verifactu controls billing systems. E-invoicing controls the invoice itself. Most businesses will need both.
- Verifactu: rules for certified billing systems so records cannot be altered in secret. It adds a QR code and a verification phrase on the invoice, timestamps, and an event log. Real-time send to AEAT is optional.
- Dates: software vendors by 29 Jul 2025, companies by 1 Jan 2026, autónomos by 1 Jul 2026.
- Practical tip: choose one toolset that is Verifactu-ready and B2B e-invoice-ready, including UBL "copia fiel" and state reporting.
Digital invoice 2025: what changed this year
2025 sharpened UBL, state reporting, and interoperability.
- The second hearing confirmed that the "copia fiel" is UBL only and that private platforms must send it to the public solution.
- It clarified how to calculate payment terms and how to structure rejection and payment states.
The benefits in one short paragraph
Spain processed around 558 million B2B e-invoices in 2024, up about 21% year over year, with estimated savings above €4.3 billion. Expect faster payments, fewer errors, less paper, and better cash visibility.
Sanctions and a simple compliance checklist
- Sanctions: up to €10,000 if you are required to offer e-billing to users and do not. Other billing breaches can lead to administrative or tax penalties.
Checklist to pass:
- Use a supported syntax and validate against EN 16931.
- Guarantee authenticity, integrity, and timestamps.
- Send and receive through a compliant private platform or the public solution.
- Ensure the UBL "copia fiel" reaches the public platform.
- Report acceptance, rejection, and payment states within 4 days.
- Retain all e-invoices for at least 4 years.
Bottom line
Spain is moving from B2G-only to economy-wide e-invoicing.
If the Order lands in late 2025, expect 2026 for over €8M and 2027 for €8M or less. SMEs will likely report states from 2028. Verifactu has hard dates in 2026, so pick software that covers both now.
Choose tools that support UBL, CII, EDIFACT, and Facturae, send the UBL "copia fiel," and handle state reporting. A Verifactu-ready stack keeps you safe for 2026. Adopting early makes the mandatory electronic invoice much simpler.
