(Published 8 February 2024. Updated 18 August 2026)
New electronic invoicing regulation is under way for Spanish businesses, though the road to get there has been longer, and slower, than first announced.
Law 18/2022 (first approved in September 2022) outlines the e-invoicing expectations and obligations for Spanish businesses. According to the official text, the regulation aims to “promote the use of electronic invoices” to digitize business relationships, lower transaction costs, facilitate transparency, and reduce the impact of late payments.
Since this law was passed, its implementing rules have been delayed twice, and a related but separate software-certification requirement has been postponed twice as well. Both tracks are now expected to land in 2027 and 2028 rather than the original 2025/2026 window. Here’s where things actually stand.
Spain’s e-invoicing push runs on two parallel regulatory tracks that are easy to conflate but legally distinct:
1. The B2B e-invoicing mandate (Law 18/2022, developed by Real Decreto 238/2026) requires structured electronic invoices, not just PDFs, between businesses, phased in by company size.
2. The SIF / Verifactu software-certification requirement (Royal Decree 1007/2023, as amended) governs the invoicing software itself: it must be certified to guarantee that billing records are tamper-proof, traceable, and reportable to the Tax Agency in near real time. This applies by taxpayer type (corporate vs. everyone else), not by revenue.
Both are real obligations businesses need to plan for. Neither is on the timeline originally announced.
Real Decreto 238/2026 was approved on March 25, 2026 and published in the BOE on March 31, 2026, entering into force 20 days later. It sets out how the system will work, but the compliance countdown for businesses only starts once a separate ministerial order (defining the technical requirements) is published. As of mid-August 2026, that order still hadn’t been issued, so the exact compliance dates remain provisional:
We’ll update this article with firm dates as soon as the order is published. In the meantime, treat any specific month you see quoted elsewhere as an estimate, not a confirmed deadline.
Unlike the B2B mandate, the Verifactu timeline is set in law and has already been revised twice:
The second delay came with roughly two weeks’ notice before the original January 2026 deadline. A pattern worth watching if you’re timing a software migration around it.
From those 2027 dates onward, any invoicing software that fails to meet the certification criteria will be considered non-compliant, and the Tax Agency can fine the business using it (see below).
Electronic invoicing (e-invoicing) is the process of sending and receiving invoices digitally, in a structured format that software can read and process automatically, as opposed to a scanned or emailed PDF.
As the financial world becomes more technological, more countries and jurisdictions are looking into the benefits of e-invoicing. To address growing concerns and challenges surrounding financial management in European businesses, many countries in the region are turning to mandatory B2B electronic invoicing.
A mandatory B2B electronic invoice mandate necessitates the use of electronic invoicing systems that allow for greater efficiency through improved data sharing and automation capabilities.
In Spain specifically, e-invoicing regulation is overseen by the Ministry of Economic Affairs and Digital Transformation, the Ministry of Finance, and the Spanish Tax Agency. As of August 2026, the relevant legislation includes:
Under this legislation, electronic invoices must adhere to a specific structure and include certain mandatory information. To comply, your business must ensure the authenticity of origin, the integrity of content, and the legibility of the invoice, from the point of issue to the end of the storage period.
Electronic invoicing comes with several benefits for B2B use cases, particularly in terms of boosting overall business resilience and productivity.
Three key advantages of B2B electronic invoices:
Beyond these general benefits, Spain’s e-invoicing regulations aim to reduce administrative burden, optimize financial management, improve tax control, and enable more efficient information exchange between businesses.
The mandatory e-invoicing regulation applies to all businesses and professionals engaged in B2B transactions in Spain, phased in by the €8 million turnover threshold described above.
Under the final text of Real Decreto 238/2026, the confirmed exemptions are narrower than earlier drafts suggested:
Providers of electronic invoicing software must ensure the certification of their systems.
Specifically, the entity or individual responsible for developing the software must certify its compliance with the applicable regulations and specifications through a responsible declaration, in the form approved by ministerial order.
These programs must guarantee the integrity, preservation, accessibility, readability, traceability, and unalterability of billing records. The crucial component is the system’s secure capability to generate and store those records.
Electronic invoicing software must particularly ensure:
It’s worth keeping the two tracks’ penalties separate, since they’re often quoted interchangeably:
Verifactu / SIF non-compliance: once the 2027 deadlines above take effect, the Tax Agency can fine a business (ERP/software user) up to €50,000 per fiscal year merely for using non-certified invoicing software. Software vendors who produce or sell non-compliant systems face a separate fine of up to €150,000 per year, per system type.
B2B e-invoicing mandate non-compliance (Law 18/2022): failing to issue a structured e-invoice, or denying a client access to one, carries its own, lighter fine schedule. Roughly €3,000 to €10,000 depending on the specific violation.
Because the Verifactu deadline has moved to January/July 2027, the €50,000 exposure isn’t live yet, but it will apply retroactively to that date once it is.
For providers of Enterprise Resource Planning (ERP) software, electronic invoicing represents both a compliance challenge and a competitive opportunity. ERPs should be ready to introduce features allowing users to issue and receive electronic invoices, preferably on a unified platform, well ahead of their applicable deadline.
Through the right electronic invoicing solution, ERPs can generate additional revenue, enhance customer retention, and foster loyalty with a seamless user experience.
A few developments beyond the headline dates are worth flagging for anyone tracking this closely:
A significant change for businesses and professionals will be the obligation to track the various stages of an invoice, with a particular focus on payment validation, through the electronic invoicing system.
These added procedures might pose challenges for businesses unless integrated with payment solutions that automate the new reporting obligations.
ERPs can seize the opportunity to empower their clients to automate payment and reporting operations through a unified platform. To sum up, ERPs can expect:
Powens solutions, such as IBAN accounts and payment methods, are the ideal way to streamline payment transactions, ensure compliance, and provide instant bank reconciliation.
This service allows ERP end-users to have an IBAN account (after a successful onboarding process), offering various functionalities, including the automatic settlement of electronically issued or uploaded invoices in the ERP.
The process is quick, simple, and entirely automated, guaranteeing efficient reconciliation of payments for these invoices in the ERP-linked account.