Order HAC/1028/2026 entered into force on 6 October 2026, setting the timetable for mandatory electronic invoicing between businesses and professionals under the Crea y Crece Act (Act 18/2022). The reform aims to digitise commercial transactions and improve the monitoring of late payments.
Implementation timetable
- 6 October 2027: Businesses and professionals whose turnover for VAT purposes exceeded €8 million in the preceding calendar year must issue and receive electronic invoices and report invoice and payment statuses.
- 6 October 2028: All other businesses and professionals must issue and receive electronic invoices. Companies and other entities subject to the reporting requirements must also begin reporting invoice and payment statuses.
- 6 October 2029: Self-employed individuals and entities under the income attribution regime with turnover not exceeding €8 million must begin reporting invoice and payment statuses. Their obligation to issue and receive electronic invoices will already have applied since October 2028.
What changes?
The obligation generally applies to transactions between businesses and professionals where the recipient is established in Spain or the transaction relates to the recipient’s Spanish permanent establishment, subject to the legal exceptions.
Sending a PDF by email will no longer be enough: invoices must use a structured, machine-readable format that enables automatic processing. Businesses may use the Spanish Tax Agency’s free public solution or a compliant private platform. When a private system is used, a faithful electronic copy must also be submitted to the public solution.
For the first twelve months, those subject to the rules from 2027 must also provide a readable PDF alongside their electronic invoices, unless the recipient expressly agrees to receive them in the original structured format.
Invoice and payment reporting
The recipient must report commercial acceptance or rejection of an invoice and the relevant date, as well as its full effective payment and payment date. The general deadline for mandatory status reporting is four calendar days, excluding Saturdays, Sundays and national public holidays. The reported payment date must reflect when payment is actually received, rather than when financing merely becomes available.
Not the same as VERI*FACTU
VERI*FACTU and the rules governing invoicing software address the integrity and traceability of records. The B2B e-invoicing standard governs the structured exchange of invoices and the reporting of statuses and payments. Compliance with one set of rules does not automatically ensure compliance with the other.