Mandatory e-invoicing in Spain: when it applies to you

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Enter your prior-year turnover, legal form and customers: the checker gives the date on which B2B e-invoicing becomes mandatory for you.

As defined in art. 121 of the VAT Act

Legal form

B2B e-invoicing mandatory from

6 October 2028

Up to €8,000,000: 24 months after Order HAC/1028/2026 (RD 238/2026, fourth final provision 1.b).

Report status and paymentMandatory from 6 October 2029
PDF alongside the invoice until–
Accepted formatsUBL (EN 16931), UN/CEFACT CII, EDIFACT, Facturae
Free optionAEAT public solution

Dates calculated by us from 6 October 2026 (entry into force of Order HAC/1028/2026, BOE of the 5th). Non-qualified simplified invoices are excluded (art. 4).

How this is calculated

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

B2B e-invoicing in Spain becomes mandatory in two phases counted from the entry into force of Order HAC/1028/2026 on 6 October 2026, under the fourth final provision of Royal Decree 238/2026. After twelve months for businesses whose turnover exceeded 8 million euros in the previous calendar year, measured as in article 121 of the VAT Act; by our calculation, 6 October 2027. After twenty-four months for everyone else, 6 October 2028. The mandate covers invoices to businesses with their seat, a permanent establishment or residence in Spain, including when the customer or a third party issues them. Excluded are non-qualified simplified invoices, invoices to consumers and foreign customers, and some transactions in the electricity and gas markets and air transport clearing houses. During their first year, large businesses will send a legible PDF with each invoice unless the customer accepts the original. Self-employed people up to 8 million may report invoice status voluntarily for twelve more months.

The two phases and their dates

Dates calculated by us by adding the RD 238/2026 periods to the entry into force of Order HAC/1028/2026. FP: final provision; TP: transitional provision.
WhoMandatory fromSpecial featureBasis
Turnover above €8,000,0006 October 2027PDF alongside the invoice until 6 October 2028, unless the customer accepts the originalFP 4.1.a and TP 2
Companies up to €8,000,0006 October 2028Invoice status reporting mandatory from the startFP 4.1.b
Self-employed and joint ownerships up to €8,000,0006 October 2028Status reporting voluntary until 6 October 2029FP 4.1.b and TP 3

The fourth final provision of RD 238/2026 defers effective application and counts it from the entry into force of the ministerial order on the public solution. That order is Order HAC/1028/2026, which came into force on 6 October 2026, the day after publication. The threshold uses the turnover of the immediately preceding calendar year.

Who is excluded

Article 3 limits the mandate to invoices to businesses with their seat, a permanent establishment or residence in Spain, and article 4 exempts non-qualified simplified invoices. The second additional provision leaves out the activities of the electricity market operator and the organised gas market, and invoices settled through the clearing houses of the international air transport association. Invoices to consumers follow another rule, article 2 bis.4 of Law 56/2007.

Once caught, the customer has 4 days to report payment. Try the deadline:

Report by

Report by

13 December 2027

Start date4 December 2027
Who reportsThe recipient
Required dataAcceptance or rejection and date
Status and payment calculator →

How to prepare now

Three steps work for either phase. First, work out this year’s turnover, because it decides your phase the following year. Second, ask your invoicing provider whether it will issue in one of the accepted syntaxes and whether it will connect to a private platform or the public solution. Third, review how you record payments: as a customer you will have to report each full payment with its date, and as a supplier you will be able to see in the public solution when you are paid. If you are close to the threshold, plan for the earlier date.

An EU condition worth watching

Law 18/2022 made the entry into force of its article 12, which imposes the general duty, conditional on obtaining an EU derogation from articles 218 and 232 of the VAT Directive, as the note in the consolidated text recalls. The preamble of RD 238/2026 states that it is consistent with Directiva (UE) 2025/516, de 11 de marzo de 2025, which amends that directive. We give the dates as they follow from the published rules; if a later decision changed them, we will reflect it. More detail in B2B e-invoicing, in the guide for the self-employed and in the timeline.

Common questions

Which turnover counts for the 8 million threshold?

That of the immediately preceding calendar year, measured under article 121 of the VAT Act: the total amount, excluding the VAT itself, of goods and services supplied in your business. It is the same figure the tax office uses for other VAT duties. If you exceed it, you fall in the first phase even if you invoice other businesses only a little.

Why do you say the dates are your own calculation?

Because the BOE gives no specific day: RD 238/2026 sets periods of twelve and twenty-four months from the entry into force of the order on the public solution. Order HAC/1028/2026 came into force the day after its publication on 5 October 2026. Adding the months gives our dates; if the Tax Agency publishes another reading, we will adopt it.

Are simplified invoices or receipts covered?

No, unless they are qualified simplified invoices. Article 4 of RD 238/2026 exempts transactions documented with a simplified invoice under article 4 of the Invoicing Regulation. Qualified ones are those where a business customer asks for its tax ID and address to be shown in order to deduct VAT; those will have to be electronic once the mandate reaches you.

When will the Tax Agency’s public solution be available?

RD 238/2026 requires it to be available at least 2 months before the first effective application. With our dates, that means no later than 6 August 2027. It will be free to use and will serve to issue, receive and keep a copy of every invoice, as well as to report payments. Its technical use is governed by Order HAC/1028/2026.

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