# Spain B2B eInvoicing: Deadlines, Formats, and Payment Reporting

> Spain’s B2B eInvoicing starts October 6, 2027 for companies above €8M, 2028 for the rest. Learn what the rules require and what your systems need to handle.

Type: Blog post
Published: 2026-10-15
Author: Luis Coll
Author role: VP of eInvoicing Compliance
Topic: regulation
Country: spain
Tags: compliance, spain

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Spain published the last legal piece of its B2B eInvoicing mandate on October 5, 2026, and it entered into force the next day, which started the clock. The mandate comes from Ley 18/2022, known as Ley Crea y Crece. If your annual volume of operations exceeds €8 million, your obligations start on October 6, 2027. Everyone else follows on October 6, 2028. You’ll need to issue and receive structured invoices, and report what happens after you receive them. None of this is VERI\*FACTU, which is a separate obligation with its own dates. The AEAT has started publishing technical documentation on its developer portal, including the web services catalogue and a preproduction WSDL, so the planning work should start now.

![spain-einvoicing-timeline.svg](https://assets.invopop.com/web/2026/10/d3d0ae62d3335fea85bc8de5.svg)---

## **Spain’s invoicing rules, and which one is which**

Over the past decade, Spain has introduced one invoicing obligation after another, and the pace picked up in the last few years. These rules come from different laws, sit in different parts of your process, and arrive on different dates. Most companies are subject to more than one, and several of them are routinely mistaken for each other.

This article explains the newest of them in full, the B2B eInvoicing mandate: the format you send your customer, the copy that reaches the Agencia Estatal de Administración Tributaria (AEAT), and the payment information the buyer reports afterward. Before that, here is a quick breakdown of the obligations, so you know which ones apply to you.

| **Rule** | **What it covers** | **When** |
| --- | --- | --- |
| **B2B eInvoicing mandate** | Invoices between businesses established in Spain | October 2027 above €8M, October 2028 for the rest |
| **VERI\*FACTU** | Invoicing software and its records, for anyone issuing invoices | January and July 2027; deferral to October 2028 announced |
| **SII** | VAT ledgers, for large taxpayers and VAT groups | In force since 2017 |
| **TicketBAI** | Invoicing software, for businesses taxed in the Basque provinces | Already in force |
| **Facturae** | Invoices to Spanish public bodies | Since 2015 |

**VERI\*FACTU** is the one most often confused with the new mandate, and the distinction matters. The underlying regulation is the Reglamento de requisitos de los sistemas informáticos de facturación (RRSIF), which governs the software you invoice with rather than the invoice you send. The software has to produce a record of every invoice that cannot be altered or deleted afterward, with each record linked to the one before it.

VERI\*FACTU is one of two ways to comply. In **VERI\*FACTU mode**, your software sends each record to the AEAT as it is created. In **non-VERI\*FACTU mode**, the records stay in your system, subject to stricter integrity, traceability, and event-logging requirements, and the AEAT can require them later. Both modes require a QR code on the invoice. Non-VERI\*FACTU puts more of the burden on your own systems.

The dates have moved repeatedly. They were set at January 1, 2027 for corporate income tax payers and July 1, 2027, for everyone else. On October 5, 2026, the Ministry of Finance announced a deferral to October 2028 for both groups, aligning VERI\*FACTU with the second wave of the B2B mandate. That deferral has not yet been published in the BOE.

**SII** is a VAT reporting regime rather than an invoicing one. It sends ledger data to the AEAT within a few days of issue, applies to a narrower set of taxpayers, and is unchanged by the new mandate.

**TicketBAI** is the Basque equivalent of the invoicing-software rules. **Facturae** covers the public sector and stays where it is.

Complying with one of these does not cover the others. Sending an invoice or a copia fiel to the public solution does not by itself satisfy your invoicing-software obligations, and a company above €8 million could be subject to the B2B mandate, VERI\*FACTU, and SII at once, with three different dates and three different parts of its stack.

## **Spain’s B2B eInvoicing mandate**

The B2B eInvoicing mandate requires businesses and professionals in Spain to exchange structured invoices with each other, and to report back on the invoices they receive. It comes from Ley 18/2022, known as " Ley Crea y Crece." The law has two purposes. The first is to move invoices out of PDF and paper and into structured data. The second is to reduce late payment, which is why this mandate carries a reporting layer that other eInvoicing regimes do not: the Spanish authorities want visibility into how long businesses actually take to pay each other.

Three legal texts define the framework:

- **Ley 18/2022:** Article 12 introduces the B2B obligation by amending Article 2 bis of Ley 56/2007.

- [**Real Decreto 238/2026**](https://www.boe.es/eli/es/rd/2026/03/25/238/con)**:** Sets the scope, formats, platform requirements, and invoice-status obligations.

- [**Orden HAC/1028/2026**](https://www.boe.es/eli/es/o/2026/10/02/hac1028)**:** Defines the technical and functional rules for the *solución pública de facturación electrónica*, managed by the AEAT.

The order was published on October 5, 2026, and entered into force the following day. That is what started the implementation periods, and it is why the mandate now has fixed dates rather than conditional ones.

### **Two obligations, not one**

The mandate has two separate duties.

1. **eInvoicing.** You issue invoices to your business customers as structured data, and you receive structured invoices from your suppliers. Being mostly a buyer does not exempt you.

2. **Payment reporting.** When you receive an invoice, you report what happened to it: whether you rejected it, the date you paid it in full, and the payment due date. This is how Spain plans to measure late payment.

For most companies the second duty is the harder one. The invoice and the payment date sit in different places: one in the system that receives your invoices, the other in accounts payable or treasury. The report to the AEAT needs both, matched to each other, within four days of payment, which is why your systems need to connect.

## **Who is in scope**

The mandate applies to invoices you are required to issue under Spanish invoicing rules, when the customer is a business or professional established in Spain. Established means the recipient’s business headquarters, permanent establishment, or failing those, domicile or habitual residence is in Spain, and the transaction is directed to that location.

[Article 4 and the additional provisions of Real Decreto 238/2026](https://www.boe.es/eli/es/rd/2026/03/25/238/con) provide exceptions, including:

- Simplified invoices, except qualified simplified invoices.

- Specified regulated activities of electricity and organized gas market operators.

- Certain invoices settled through designated International Air Transport Association (IATA) clearing systems, subject to the conditions in the decree.

Sales to consumers are not covered either. This is a B2B mandate, so invoices to private individuals stay outside it, though your invoicing software obligations under VERI\*FACTU apply regardless of who the customer is.

The Basque Country and Navarra have their own tax arrangements. The decree provides for cooperation between the Haciendas Forales and the AEAT on the public solution, so these territories should not be treated as blanket exclusions.

Being in scope does not tell you when you start. That depends on your volume of operations, and the timeline below sets out the dates.

## **The timeline**

The implementation periods run from October 6, 2026, the day the ministerial order entered into force. The €8 million threshold uses your volume of operations in the immediately preceding calendar year, calculated under Article 121 of Spain’s VAT law. Businesses above it are in the first wave.

| **Timing** | **What starts** |
| --- | --- |
| October 6, 2026 | The ministerial order enters into force and starts the implementation periods. |
| At least 2 months before the first application date | The solución pública de facturación electrónica must be available. |
| October 6, 2027 | Issuing, receiving, and reporting obligations start for businesses and professionals whose volume of operations exceeded €8 million. Private-platform copy-submission and interconnection obligations also take effect. |
| October 6, 2028 | Issuing and receiving obligations start for the remaining businesses and professionals. Reporting obligations also start, except for the group with an additional transition period below. |
| October 6, 2029 | Mandatory invoice-status and payment reporting starts for individuals and entities under the personal-income-tax income-attribution regime whose volume of operations did not exceed €8 million. Reporting is voluntary for this group before then. |

These dates follow the 12- and 24-month periods in the decree’s[ final provision four](https://www.boe.es/eli/es/rd/2026/03/25/238/con), plus the additional reporting transition in transitional provision three.

For the first 12 months of their obligation, businesses above the threshold must also send a PDF copy to the recipient, unless the recipient voluntarily and expressly agrees to receive the original structured format alone. The PDF is not sent to the public solution.

Subcontractors covered by the existing public-contract invoice-register requirement have 24 months from the order’s entry into force to adapt to the new system.

## **Sending and receiving invoices**

You can use a private platform, the public solution, or both.

A private platform (plataforma privada de intercambio de facturas electrónicas) handles invoice exchange with your customers and suppliers. Platforms must interconnect with other participating platforms when a client asks, without charging for that interconnection.

The public solution (solución pública de facturación electrónica) is the AEAT’s free route for generating, exchanging, and accessing invoices, and it is also the repository for every invoice covered by the mandate. Under[ Articles 3–5 of the ministerial order](https://www.boe.es/eli/es/o/2026/10/02/hac1028), you generate invoices there through a web form, one at a time, while interconnection and copy submission use web services.

### **What is the copia fiel?**

If you issue an invoice outside the public solution, your platform has to send the AEAT an electronic *copia fiel* of it, in UBL, at the same moment you issue it. The copy has to carry the required invoice content and be identified as a copy.

So you could exchange a CII invoice with your customer while your platform sends the matching UBL copy to the AEAT. The invoice your customer receives and the copy the AEAT receives do not have to be in the same syntax.

If you use the public solution to issue or interconnect the original invoice, no separate copy is needed.

![Flow 1.gif](https://assets.invopop.com/web/2026/10/a4ee1badef40899176cb9980.gif)A rejected copy does not invalidate the invoice. If the AEAT rejects a *copia fiel* for failing validation, the original invoice you sent your customer remains valid. You correct the cause of the rejection and send the copy again.

Private platforms can also use the public solution to exchange invoices with each other. If the link between two platforms is not ready, your platform can deposit the invoice in the public solution and your customer’s platform retrieves it from there. Platforms must automate that retrieval and pass the invoices to their customers immediately.

## **eInvoice formats** 

The decree requires structured invoices aligned with EN 16931, the European invoice-data standard. It permits four syntaxes: UBL, UN/CEFACT CII, EDIFACT invoice messages, and Facturae.

Peppol BIS messages remain valid between private platforms, because they use UBL and follow EN 16931.

Private platforms must be able to convert between the accepted formats while preserving authenticity and integrity. Invoices issued through private platforms require an advanced electronic signature. The issuer and recipient can agree on the syntax and technical specifications for their exchange; without an agreement, the public solution’s specifications apply.

The public solution and the copia fiel use UBL 2.5, with the Spanish content requirements defined in the[ ministerial order’s Annex I](https://www.boe.es/eli/es/o/2026/10/02/hac1028). Invoices and copies submitted there cannot contain embedded files.

The invoice itself carries a field for the VERI\*FACTU or TicketBAI QR code where the applicable rules require one, so the two regimes meet inside the same document even though they remain separate obligations.

Your preparation should cover both the structured data your billing system provides and the conversion, signature, and submission work your platform handles.

## **Reporting invoice status and payment**

Receiving structured invoices brings reporting duties too. The framework distinguishes status information sent to the issuer through private exchange from reporting to the public solution.

| **Reporting route** | **Required information** | **Timing** |
| --- | --- | --- |
| To the issuer under Article 10 | Commercial acceptance or rejection and its date; full payment and its effective date. | Within 4 days of the reported event, excluding Saturdays, Sundays, and national holidays. |
| To the public solution under Article 12 | Rejection, where applicable; full payment and its effective date; and the payment due date. | Full payment must be reported within 4 days of its effective date, excluding Saturdays, Sundays, and national holidays. |

The public-solution reporting duty applies regardless of which route you used to exchange the invoice. You can authorize your private platform to report payments on your behalf, provided you give it the necessary data.

How many reports you send depends on the route. If the invoice travelled through a private platform, you report twice: once to the issuer through the platform, and once to the public solution. If it travelled through the public solution, you report once, to the public solution.

![Flow 2.gif](https://assets.invopop.com/web/2026/10/7c7806e7156c13011fa61903.gif)The public solution presumes acceptance unless there is a rejection or a subsequent corrective invoice. The issuer can voluntarily report collection, nonpayment, or discrepancies with the buyer’s reported payment dates.

These distinctions are set out in[ Articles 10–12 of the decree](https://www.boe.es/eli/es/rd/2026/03/25/238/con) and Article 7 of the ministerial order.

Operationally, you need to connect each received invoice to its commercial status, due date, and full-payment date. If those fields live in separate accounting or treasury tools, decide how they will reach your reporting workflow.

## **Penalties**

[Article 2 bis(9) of Ley 56/2007](https://www.boe.es/buscar/act.php?id=BOE-A-2007-22440) provides for a warning or a fine of up to €10,000 for specified failures, including not offering electronic invoice receipt when required and preventing former customers from accessing their invoices.

That is not a universal €10,000 cap on every breach of the B2B framework. The relevant obligation and the sanction attached to it need to be read together.

Neither the decree nor the order adds a new penalty. How the existing rule applies to each B2B obligation is not yet confirmed.

## **How to prepare for Spain eInvoicing**

The AEAT has also published the first technical documentation for the public solution: the web services catalogue, the input and output formats, and the service definitions for preproduction. You should start preparing now.

Start by mapping the full invoice lifecycle, from issue and receipt to payment reporting.

1. **Confirm your scope and deadline:** Check the transactions you invoice, your prior-year volume of operations, and whether a reporting transition or exception applies.

2. **Map your data:** Identify where invoice details, commercial acceptance or rejection, due dates, and full-payment dates are recorded. Include accounts payable and treasury in the project.

3. **Choose your exchange route:** Assess the public solution, a private platform, or both. For a private platform, check format conversion, signatures, interconnection, copia fiel submission, and invoice retrieval.

4. **Assign reporting responsibility:** Decide who supplies each status field and who submits it. Then check who can actually act with the AEAT: the public solution requires an electronic certificate valid in the AEAT’s Sede electrónica, with Cl@ve accepted only in the forms. A third party can act for you under the ordinary tax representation rules, including a tax adviser under a social collaboration agreement, but to use the forms or the retrieval and consultation services on your behalf they have to be registered in the AEAT’s Registro de apoderamientos.

5. **Plan validation and exception handling:** Follow the AEAT’s developer portal, where the technical documentation is being published, and watch for the test environment. Your workflow should handle rejected submissions and corrections, as well as successful delivery.

## **Get ready for Spain eInvoicing with Invopop**

Spain’s B2B mandate adds invoice exchange and payment reporting to a landscape that already includes VERI\*FACTU, TicketBAI, SII, and Facturae. Your preparation should bring these requirements into one plan, covering the systems you use to issue invoices, receive them, and record payments.

Navigating Spain's B2B eInvoicing mandate alongside other evolving requirements across the market you operate in is complex. We already support[ VERI\*FACTU, TicketBAI, SII, and Facturae](https://invopop.com/coverage/spain), and we are building for the B2B mandate as the specifications are released. Connect your billing or ERP system to our platform once to send, receive, and report compliant eInvoices in 30+ countries, and manage all of them in one place.

Spain's B2B timeline is now fixed, and the next months are for planning and building: map your flows, pick your route, and prepare your payment data.[ Talk to our team](https://invopop.com/contact/) about your current setup, what needs to change, and how to plan your implementation.

## **FAQ about Spain eInvoicing**

:::faq
## **Can I keep sending PDF invoices?**

A PDF alone does not meet the structured-invoice requirement. Businesses above the €8 million threshold must send a PDF alongside the structured invoice during their first 12 months, unless the recipient expressly agrees to receive only the original structured format.

## **Do I have to use the public solution to issue invoices?**

You can use a private platform. If your invoice is issued and exchanged outside the public solution, your system must send a UBL copia fiel there simultaneously. Using the public solution to issue or interconnect the original invoice removes the separate-copy requirement.

## **Do smaller sole traders have until 2029 to issue eInvoices?**

Their issuing and receiving obligations start in October 2028. The additional year applies to invoice-status and payment reporting for the specified individuals and income-attribution entities at or below the €8 million threshold.

## **Does meeting the B2B mandate also satisfy VERI\*FACTU requirements?**

No. The two frameworks are separate. Structured invoice exchange and payment reporting do not replace the requirements that apply to your invoicing software and its records.

## **When will the AEAT open the test environment?**

The AEAT has not announced a date, but the preproduction service definitions are already published, including a WSDL and a validation service that works only in preproduction. The public solution itself has to be available at least two months before the first application date.

:::

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