E-invoicing in Spain: what it is and which one applies in 2026

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Choose who you invoice: the tool tells you whether you already need structured e-invoices, from when, in which format and through which channel.

Form

Structured e-invoice

6 October 2028

Between businesses the mandate comes with RD 238/2026. Meanwhile, Verifactu already changes how you issue invoices, whether paper, PDF or electronic.

FormatUBL (EN 16931), UN/CEFACT CII, EDIFACT, Facturae
ChannelPrivate platform or public solution
Verifactu as wellYes, from 1 July 2027

Basis: Law 25/2013, Law 56/2007 art. 2 bis, RD 238/2026 and RD 1007/2023.

How this is calculated

Prepared by Radif Partners · Method · Rules read in the BOE and at the AEAT on 25 October 2026

Under article 9 of the Spanish Invoicing Regulation, an electronic invoice is one issued, transmitted and received in electronic form. Until now that included a PDF sent by email, as long as the customer accepted it. With mandatory B2B e-invoicing the concept narrows: Royal Decree 238/2026 requires a structured file under the European standard EN 16931, in one of four syntaxes, UBL, CII, EDIFACT or Facturae, which software can read without human intervention. Three situations coexist in Spain. For public bodies, companies and other entities must invoice in Facturae through FACe or another entry point since 15 January 2015, under Law 25/2013. Between businesses, the mandate arrives, by our calculation, on 6 October 2027 for those with turnover above 8 million euros and on 6 October 2028 for everyone else. For consumers there is no general mandate: only certain large service companies must offer it to those who accept. Verifactu is separate and applies to every invoice, paper or electronic.

Three recipients, three sets of rules

B2B dates calculated by us from Order HAC/1028/2026.
Invoices toMandateFormatRule
Public bodiesCompanies and other entities, since 15 January 2015Facturae 3.2.2, signedLaw 25/2013, art. 4
Businesses in Spain6 October 2027 or 6 October 2028, by turnoverUBL (EN 16931), UN/CEFACT CII, EDIFACT, FacturaeRD 238/2026
ConsumersOnly certain large service companies, if the customer acceptsAnyLaw 56/2007, art. 2 bis.4

Law 25/2013 has been in force for more than ten years: public and private limited companies, foreign entities with an establishment in Spain, temporary joint ventures and the other entities in its article 4 must invoice public bodies electronically, and each body may exempt invoices up to €5,000. The self-employed may do so but the law does not require it. The format is Facturae with an advanced electronic signature, filed through FACe or the entry point of each regional or local administration.

What changes with the B2B mandate

RD 238/2026 implements Law 18/2022 and defines the mandatory e-invoice as one issued, transmitted and received in structured electronic form, following the EN 16931 model and in one of the syntaxes of its article 7. Beyond the format it brings two new features: every invoice must reach the Tax Agency’s public solution, as the original or as a faithful copy in UBL, and the customer must report whether they accept or reject it and when they pay it. The stated aim is to cut late payment between businesses, which the law treats as a major problem for small firms.

Which format and channel apply depends on the recipient:

Format and signature

Format and signature

Facturae 3.2.2

Mandatory since15 January 2015
Unique identifierFACe registry number
StatusesPublished by FACe
Formats and signature in detail →

And where does Verifactu fit?

Verifactu is not an invoice format but a rule about the software that issues it. It applies to all your invoices, paper and consumer invoices included, if you produce them with software. A B2B e-invoice issued with adapted software will therefore carry its Verifactu record and QR and also travel as a structured file. The differences are explained in what Verifactu is. To see whether the mandate applies to you, use the mandatory e-invoicing checker; to choose a format, Facturae or B2B e-invoice; and for public bodies, FACe. Law 56/2007 sets out the general duty for businesses in its article 2 bis.

Common questions

Is a PDF sent by email an electronic invoice?

Today yes, in the sense of article 9 of the Invoicing Regulation, if the customer has consented and authenticity and integrity are guaranteed. But it does not meet the B2B e-invoicing mandate, which requires a structured file under EN 16931. During the first year, large businesses will send a PDF alongside that file, which does not replace it.

Do I need my customer’s consent to send an e-invoice?

Outside the mandate, yes: article 9.2 of the Invoicing Regulation makes e-invoicing conditional on the recipient accepting it. In the mandatory cases of the new article 8 bis, added by RD 238/2026, that consent is no longer needed. Public bodies do not need to consent either, because Law 25/2013 requires certain entities to invoice them electronically.

What is the EN 16931 standard the regulation mentions?

It is the European standard defining the semantic model of an e-invoice: which data it carries and what they mean, such as number, date, parties, lines and taxes. It is not a file format itself; the UBL and CII syntaxes express it in XML. RD 238/2026 requires every mandatory invoice to follow that model.

Must invoices to foreign customers be electronic?

Not under RD 238/2026. Its article 3 applies the mandate when the recipient is a business with its seat, a permanent establishment or its residence in Spain. For customers in other countries you can keep sending invoices in whatever format you agree, respecting the mandatory content and, if you are caught, the Verifactu record.

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Publisher of free tools on Spain's Verifactu and e-invoicing rules: eligibility check, QR reader, Facturae creator and timeline, all in your browser

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As of 2026, rules read in the BOE and on the AEAT website on