Spain’s mandatory B2B e-invoicing regime now has a confirmed implementation timetable. For businesses, the main challenge is practical: adapting invoicing software, monitoring payments and organising internal processes.
1. The rules and obligations for businesses
Law 18/2022 introduced mandatory electronic invoicing between businesses and professionals. Royal Decree 238/2026 and Order HAC/1028/2026 provide the implementing and technical rules. A PDF sent by email will not, on its own, meet the new structured e-invoicing requirements.
The regime starts on 6 October 2027 for businesses and professionals with VAT turnover exceeding €8 million in the preceding year; on 6 October 2028 for the remaining businesses and professionals. Reporting of invoice and payment statuses for the remaining individuals and income-attribution entities begins on 6 October 2029. Different transitional reporting rules therefore apply according to the type of business.
For the first 12 months of application to businesses above the €8 million threshold, invoices must also be accompanied by a readable PDF, unless the recipient expressly agrees to receive only the structured invoice. This PDF is supplementary and does not replace the electronic invoice.
The rules also introduce obligations to report invoice statuses and payments. Once an invoice has been paid in full, the recipient must report the payment and its effective date within four days, excluding Saturdays, Sundays and national public holidays, when the corresponding reporting obligation applies.
This means companies must be able to identify paid, outstanding and disputed invoices accurately, and coordinate invoicing with their accounting and treasury records.
2. Businesses can keep their existing software
The Spanish Tax Agency (AEAT) will offer a free public invoicing solution. Businesses may continue using private software, provided it complies with the new technical and interoperability requirements. Where an invoice is issued through a private platform, a faithful copy must also be submitted to the public solution.
The priority is to check that software can exchange structured invoices, identify users securely, transmit copies and reconcile records with accounting. Companies should request a written adaptation plan from their provider, covering connectivity, testing, error handling and responsibilities—not merely an assurance that the system is “e-invoicing ready”.
3. How should companies prepare?
The most effective starting point is to review how invoices are currently issued, received and paid. Businesses should identify the domestic B2B transactions covered, confirm their implementation deadline and map each step from issuing an invoice through to recording its payment.
They should then request a specific implementation timetable from their software provider and test whether electronic invoices can be exchanged, traced and matched with the accounting system. Customer and supplier details, payment terms and invoice references should also be reviewed to reduce errors and duplicated records.
Internal procedures will be just as important as technology. Companies should decide who verifies invoice reception, handles rejections or credit notes, records partial and late payments, and submits payment-status information where required. For businesses with several entities or billing teams, one common procedure and a clearly designated coordinator will help prevent inconsistent reporting.
Finally, finance, administration and relevant commercial teams should receive practical training before the rules take effect. Businesses must also distinguish B2B e-invoicing from the separate invoicing-software requirements, including VERI*FACTU: meeting one set of rules does not automatically mean meeting the other.
Conclusion
Preparing for e-invoicing is not simply about choosing a compliant program. It is an opportunity to improve billing workflows, payment visibility and internal controls. Early preparation will allow businesses to resolve practical issues before the mandatory deadlines.