Spain Sets Firm B2B E-Invoicing Dates: Royal Decree 238/2026 Explained
Spain has published Royal Decree 238/2026, giving its long-delayed Crea y Crece B2B e-invoicing mandate concrete dates for the first time: October 2027 for large businesses and October 2028 for everyone else.
Spain's B2B e-invoicing mandate has moved from "coming eventually" to a fixed timeline. Royal Decree 238/2026 was approved by the Council of Ministers on 24 March 2026 and published in the Boletín Oficial del Estado (BOE) on 31 March 2026, establishing the legal architecture for the mandatory B2B e-invoicing system created by Law 18/2022 ("Crea y Crece").
This is separate from — and easy to confuse with — Verifactu, the invoice software certification and anti-fraud reporting system. Verifactu's original 2026 dates were themselves postponed by one year under Real Decreto-ley 15/2025: it now becomes mandatory for companies from 1 January 2027 and for the self-employed from 1 July 2027. Royal Decree 238/2026 concerns a different, later-running track — the actual structured B2B invoice exchange mandate — which until now had no confirmed date.
The Draft Ministerial Order
The Royal Decree sets out the legal framework but defers the technical detail to a Ministerial Order. A draft of that order went to public consultation from 17 April to 8 May 2026, specifying the technical requirements for Spain's public e-invoicing solution operated by the AEAT (the Spanish tax agency), plus the accreditation rules for private platforms.
The Confirmed Timeline
| Date | What Happens |
| 1 October 2026 | Ministerial Order takes effect; all subsequent compliance deadlines start counting from this date |
| 1 October 2027 | Mandatory for businesses with annual turnover above **€8 million** |
| 1 October 2028 | Mandatory for all remaining VAT-registered businesses, SMEs, and freelancers (autónomos) |
| 1 October 2029 | Payment status reporting obligations extend to smaller entities |
Accepted Formats
Spain's system accepts four invoice syntaxes: UBL (mandatory for the public AEAT solution), plus CII, EDIFACT, and the national Facturae format for private platforms. Businesses can route invoices either through the free public AEAT platform or through an accredited private platform — a structure that echoes France's PDP/PPF split more than Italy's single-clearing-house SDI model.
Why Verifactu and the B2B Mandate Are Easy to Conflate
Getting Verifactu-compliant software in place for the 2027 deadlines does not automatically solve a business's B2B e-invoicing obligation — Verifactu only certifies that invoicing software produces tamper-proof records and reports them to AEAT; it does not require sending structured invoices to trading partners. The Crea y Crece B2B mandate, now dated for October 2027/2028, is the separate layer that actually requires exchanging structured invoices between Spanish businesses. Because Verifactu's company deadline (1 January 2027) now falls just months before the B2B mandate's first phase (1 October 2027 for large businesses), many Spanish businesses will effectively be implementing both in the same year.
What to Do Now
- Turnover above €8 million: You have roughly 15 months from the Ministerial Order's entry into force. Start vendor evaluation now — Verifactu-certified software is a starting point, not the finish line.
- Smaller businesses and autónomos: October 2028 feels distant, but vendors serving the Spanish market (Holded and others) are already building toward both Verifactu and the full B2B mandate in the same platform, so upgrading now avoids a second migration later.
Source
RTC Suite, Spain's Mandatory B2B e-Invoicing Takes Shape: Royal Decree 238/2026 and the Draft Ministerial Order; KPMG, Spain: Council of Ministers approves e-invoicing mandate for B2B transactions.
