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25 March 2026

Spanish Government approves Royal Decree implementing mandatory B2B electronic invoicing

  • On 24 March 2026, the Spanish Council of Ministers approved the Royal Decree implementing the mandatory business-to-business (B2B) electronic invoicing system in Law 18/2022 (the Create and Grow Law), which completes the regulatory framework required to implement the new system.
  • The Royal Decree establishes the legal and operational framework for electronic invoicing between businesses and professionals in Spain, introducing structured electronic invoices and mandatory reporting of invoice status as key tools to promote digitalization and combat late payments in commercial transactions.
  • The requirements will enter into force on a phased basis, calculated from the publication of the forthcoming Ministerial Order setting out the technical specifications, with larger taxpayers becoming subject to the rules earlier than smaller businesses and professionals.
 

On 24 March 2026, the Spanish Council of Ministers approved the Royal Decree developing the electronic invoicing requirements introduced by Law 18/2022. The measure applies to all transactions carried out by businesses and professionals (business-to-business or B2B) established in Spain, while transactions with final consumers (business-to-consumer or B2C) and cross-border transactions remain outside its scope.

Under the new system, invoices must be issued in a structured electronic format, meaning that issuing invoices solely in PDF format and sending them by email will no longer be sufficient, except during a limited transitional period.

A key feature of the new regime is the requirement that electronic invoice recipients must electronically report the status of invoices, including whether the invoice was accepted or rejected and paid (including the payment date).

This information must generally be reported within four days of each event, reinforcing the monitoring of payment deadlines in B2B transactions.

The Royal Decree allows a public electronic invoicing platform to be used. Private platforms can also be used if they meet interoperability requirements and invoice data can be transmitted to the public system.

The requirements will apply:

  • Twelve months after publication of the Ministerial Order for businesses with annual turnover exceeding €8m
  • Twenty-four months after publication of the Ministerial Order for all other businesses and professionals

During the first 12 months the requirements apply, electronic invoices must generally be accompanied by a readable PDF copy, unless the recipient expressly agrees to receive only the structured electronic format.

It should be noted that this Royal Decree relates exclusively to B2B electronic invoicing under the Create and Grow Law and is separate from the "VeriFactu" system, which forms part of Spain's anti-fraud legislation and follows a different implementation timeline.

Implications

This development represents a significant step in Spain's invoicing digitalization agenda and will require many businesses to review their invoicing, accounts payable and accounts receivable processes, as well as their enterprise resource planning (ERP) and payment workflows.

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young Abogados, S.L.P, Spain

Published by NTD’s Tax Technical Knowledge Services group; Andrea Ben-Yosef, legal editor

Document ID: 2026-0726

 

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