Further to the publication of article 12 of Law 18/2022 [↗︎], generally referred to as “Ley Crea y Crece”, the Spanish Government has approved on Tuesday 24th of march 2026 a Royal decree mandating the implementation of B2B e-invoicing.
The official publication of the Royal decree approved on Tuesday is strongly awaited to fully review the obligations to be implemented, notably compared to the information issued from the preliminary draft Royal decree published on January 29th, 2024 [↗︎].
This approval marks, since the law was passed in 2022, a significant step toward the long awaited implementation of the B2B e-invoicing obligations. However, to take effects, publication of the regulatory framework, thought a Ministerial Order, is expected before July 1st, 2026 in the Official State Gazette (BOE).
The official communication shared by the Ministry of Economy, Trade and Enterprise [↗︎] (“Ministerio de economia, de comercio y empresa”) provides details regarding:
- The implementation timeline,
- Confirmation of obligations in scope and B2B e-invoicing model,
- Main objectives expected and articulation with the current Veri*Factu’s project implementation.
Implementation timeline
While no fixed dates are yet defined (triggered by the upcoming publication of Ministerial order, expected before July 1st, 2026), the global implementation timeline of the B2B e-invoicing obligation is globaly confirmed and will be phased depending on businesses turnover:
- Expected around July 2027 – large businesses – Issuance, reception, and invoice status will become mandatory for businesses with turnover above 8 Million EUR within 1 year after the publication of the Ministerial order,
- Expected around July 2028 – Small and medium legal entities – Issuance, reception and invoice status will become mandatory for all other legal entities within 2 years after the publication of the Ministerial order,
- Expected around July 2028 – Sole traders – Issuance and reception will also become mandatory for legal entities within 2 years after the publication of the Ministerial order. Concerning Invoice status, review of the Royel decree will be needed to confirm the date on which Sole traders with annual turnover under 8 Million EUR will have to transmit such information (under the draft it was planned to become mandatory within 3 years after the publication of the Ministerial order but not mentioned in the latest official communication).
Since there will normally be no general obligation to receive B2B e-invoices in 2027, issuers may have to send a PDF copy together with the e-invoice during the first 12 months to recipients, especially SMEs, that are not yet required to receive them.
Confirmation of obligations in scope and B2B e-invoicing model
Based on the official communication, businesses would have to comply with three major obligations, as already indicated in the previous draft:
- Issuance, transmission and reception of B2B e-invoices
- Obligation to transmit status of each B2B e-invoice (based on the draft of the Royal decree: acceptance, rejection/refusal, within 4 business days, and payment date information)
- Transmission of B2B e-invoices data and status to the AEAT (Spanish tax authority), via the Public Platform
The proposed model is globally similar to the initial framework of the French B2B e-invoicing system, allowing businesses to choose between two options (for more detail, visit our Spain Country profile) :
- Use of certified Private platforms, which must be interconnected (direct link or using, for example, the Peppol network),
- Use of the free but limited services of the Public Platform developed by the Spanish Tax Agency (FACeB2B), accessible to any business or professional.
Along with the transmission of B2B e-invoices, data will have to be transmitted to the Spanish tax authority by businesses. The transmission method will have to be confirmed via the official publication of the Royal decree.
Main objectives expected
Aiming to combat VAT fraud, Spain already implemented since 2017 an e-reporting obligation (Suministro Inmediato de Información – SII) and currently implementing Veri*Factu (implementation facing another delay and pushed to 2027), which is a different measure coinciding with the implementation of the B2B e-invoicing obligation.
As outlined, the main intention to implement domestic B2B e-invoicing, along with the current e-reporting obligation, is to decrease late payments (actually only 20% Spanish large companies pay on time) and reduce administrative burden. As indicated in the official published on March 24th of 2026 [↗︎], “Spain has one of the longest average payment periods in the European Union (EU), at around 80 days, well above the 60-day maximum established by the Late Payment Law and the EU average”.
The implementation timeline, one year for large businesses, and the scope of obligations appears to be challenging, notably when large businesses should also ensure compliant payment processes.
