For years, mandatory electronic invoicing between businesses was a regulatory promise that kept getting postponed. That period of uncertainty ended on 31 March 2026, when Royal Decree 238/2026 (BOE-A-2026-7295) provided the technical development of the mandate contained in Law 18/2022 on the creation and growth of companies — known as the Crea y Crece Act — and set a clear calendar with no room for interpretation. If your company issues or receives invoices from other Spanish businesses or professionals, you have a legal obligation that begins in October 2027 and requires you to start preparing today.
What is B2B e-invoicing and how does it differ from a PDF invoice?
The most common misconception is equating «electronic invoice» with «sending a PDF by email». These are different things. An electronic invoice compliant with the Crea y Crece Act is a machine-readable structured document — specifically using the European semantic model EN 16931 under UBL (Universal Business Language) or CII (Cross Industry Invoice) syntax — exchanged through an accredited platform and registered in a system that guarantees its integrity, authenticity, and traceability.
A PDF is not an electronic invoice in the legal sense: it is an image of an invoice. Your software must generate, send, receive, and archive the structured file; the PDF may accompany it as a visual presentation, but the fiscal data is carried by the XML or UBL file.
Royal Decree 238/2026: what it actually regulates
RD 238/2026, published on 31 March 2026, develops Article 12 of the Crea y Crece Act and amends the Invoicing Obligations Regulation (RD 1619/2012). Its key points are:
- Personal scope: business owners and professionals established in Spain who carry out transactions with each other (B2B), regardless of amount. Transactions with end consumers (B2C) and those already covered by the SII or the FACe system for Public Administrations are excluded.
- Mandatory format: European standard EN 16931, in UBL or CII syntax. Platforms managing the exchange must be accredited or connected to the Ministry's public solution.
- Payment statuses: a relevant novelty — both issuer and recipient must record and communicate the invoice status (received, accepted, paid, unpaid) within a maximum of 4 working days from the event. This mechanism aims to reinforce the Late Payment Act and provide the Tax Agency with real data on payment timelines.
- Public solution: the Ministry of Economy will make a free public platform available to SMEs and self-employed individuals who do not have specialised software.
- Interoperability: private platforms must guarantee the exchange with any other accredited platform, preventing the «walled garden» effect of technology providers.
Final deadlines: the calendar you need to mark in red
RD 238/2026 establishes two phases of entry into force, conditional on the Ministerial Order for platform accreditation entering into force — for which RD 238/2026 sets a deadline of before 1 July 2026 — and from that point, the deadlines are:
| Company profile | Criterion | Deadline for issuing and receiving |
|---|---|---|
| Large companies | Annual turnover above 8 million euros | October 2027 (12 months after the Ministerial Order enters into force) |
| SMEs and self-employed | All other business owners and professionals | October 2028 (24 months after the Ministerial Order enters into force) |
| All companies (reception) | Regardless of size | From October 2027 if the issuer is a large company |
Critical point for SMEs: even if you are not required to issue until 2028, if a large supplier sends you electronic invoices from October 2027, you must be able to receive and process them. This means the real margin to adapt your system is shorter than it appears.
Who is obligated and who is excluded?
The regulation applies to all business owners and professionals established in Spain who carry out VAT-liable transactions with each other. This includes limited liability companies, public limited companies, self-employed individuals, and business partnerships that invoice other businesses. The following fall outside the scope:
- Invoices to end consumers (B2C).
- Transactions already managed by the SII (Immediate Information Supply) — large companies with VAT turnover above 6 million already report in real time to the AEAT, but the SII is not equivalent to B2B electronic invoicing.
- Invoices to Public Administrations, which already followed the FACe/FACeB2B system.
- Intra-community transactions and exports (although the European context is evolving towards ViDA — VAT in the Digital Age — which will affect these transactions).
The connection with Verifactu: two obligations that are not the same
Companies often confuse B2B electronic invoicing (Crea y Crece Act) with Verifactu (Regulation on invoicing information systems, derived from the Anti-Fraud Act). These are two distinct regulatory frameworks that coexist:
- Verifactu regulates the invoicing software: it requires the programme to generate records with chained HMAC-SHA256 fingerprints, which may (or must, depending on the case) be transmitted in real time to the AEAT. Following the extensions introduced by Royal Decree-law 15/2025 (BOE December 2025), the current deadlines are January 2027 for taxpayers subject to Corporate Income Tax and July 2027 for all other users.
- B2B electronic invoicing regulates the exchange between companies: the structured format, exchange platforms, and payment statuses. Its deadlines are 2027–2028.
An ERP or invoicing software that wants to be compliant in 2027 must meet both frameworks: the Verifactu record for the AEAT and the EN 16931 structured exchange for the business recipient. If your software does not yet have Verifactu approval, that is the first urgent step. You can find out in detail how to tackle this dual adaptation on our Verifactu and electronic invoicing implementation service page.
What your ERP or invoicing software must do now
The technical adaptation requires changes at the software layer, in internal processes, and in relationships with suppliers and customers. These are the specific requirements:
1. Generating invoices in structured format
Your software must export the invoice as an XML file conforming to EN 16931 (UBL 2.1 or CII D16B). Mandatory fields include, among others: tax identification of issuer and recipient, line item descriptions, taxable base, VAT rate, total amount, and payment references. Leading ERPs — Odoo, Sage, Microsoft Dynamics — already have specific modules; custom-built solutions require explicit adaptation.
2. Integration with an accredited exchange platform
Invoices are not sent directly between companies: they pass through an accredited platform acting as an exchange operator. The Ministry will provide a public option; in the market there are private operators (Basware, Tungsten, Edicom, among others) with different cost models and functionality. Your ERP must connect via API or WebService to the chosen platform.
3. Automatic reception and processing
Issuing is pointless if you cannot receive. The system must download incoming invoices from the platform, validate their XML schema, and automatically feed the accounts payable module. This means reviewing internal approval workflows so they do not depend on reading a PDF in an email inbox.
4. Recording and communicating payment statuses
This is the newest obligation and the one that requires the most process changes. Within a maximum of 4 working days, the issuing company must update the invoice status (accepted, rejected, paid) and the recipient must record when it was received and when it was paid. This requires a connection between the treasury module and the exchange platform.
5. Archiving and preservation
Electronic invoices must be preserved in their original format for the legal period (at least 4 years for tax purposes). The archive must guarantee integrity, authenticity, and readability. Converting the XML to PDF for archiving is not acceptable: the structured file must be kept.
Comparison table: current situation vs. 2027–2028 requirements
| Aspect | Typical situation today | Requirement from Oct. 2027 / Oct. 2028 |
|---|---|---|
| Issuance format | PDF sent by email | XML in EN 16931 (UBL or CII) via accredited platform |
| Reception format | PDF in inbox, processed manually | Automatic download from platform; processed by the ERP |
| Payment statuses | No obligation to communicate | Notification within ≤4 working days to the platform |
| Verifactu (AEAT record) | Mandatory from Jan. 2027 (CIT) / Jul. 2027 (others) for software users | Remains mandatory; compatible with B2B |
| Archiving | PDF in a folder or email | Original XML file preserved with integrity guarantees |
| Exchange platform | Not required | Mandatory (public or accredited private) |
How long does it take to adapt an ERP?
It depends on the starting point. An ERP such as Odoo 17 or Microsoft Dynamics 365 Business Central already has electronic invoicing modules that, with the correct configuration and integration with an accredited platform, can be operational in 4 to 8 weeks for a medium-sized company. Legacy bespoke software or a basic invoicing solution may require months of development and testing.
The Summum Sistemas teams support companies in adapting their ERP and invoicing systems to Verifactu and B2B electronic invoicing requirements, from the initial diagnosis to integration testing with platforms. We have been implementing management systems in SMEs and mid-market companies in Castilla y León and the Canary Islands since 2007.
The European context: ViDA and cross-border electronic invoicing
The Crea y Crece Act regulates electronic invoicing in domestic B2B transactions. But the European framework is advancing in parallel. The ViDA (VAT in the Digital Age) initiative, approved at Community level, plans to extend electronic invoicing and real-time reporting to intra-community transactions between companies from different EU Member States. ViDA deadlines start in 2028 for certain transactions. Companies that export or make intra-community purchases will need to prepare their systems for a dual reporting scenario: domestic (EN 16931 via Spanish platform) and intra-community (Peppol BIS Billing 3.0 towards the European Commission hub).
Frequently asked questions
Do I need to comply if I am self-employed with only a few business clients?
Yes. The Crea y Crece Act and RD 238/2026 do not establish a minimum turnover threshold for self-employed individuals: if you are a business owner or professional and you invoice other businesses or professionals, you are included. Your deadline is October 2028. Although there are low-cost platforms and even the Ministry's public solution, you must verify that your invoicing software is adapted before that date.
What happens if I fail to comply by the deadlines?
Law 18/2022 establishes a penalty regime. Infringements for failing to comply with the electronic invoicing obligation are classified as formal tax infringements, with fines ranging from €300 to 1% of the affected turnover, depending on severity and recurrence. Furthermore, if your customer is required to receive electronic invoices and you cannot issue them, you may find yourself in a situation of contractual non-compliance.
Can I use any exchange platform or do I have to use the Ministry's?
You can use any private platform that has obtained accreditation from the Ministry of Economy, Trade and Enterprise, or the public platform that the Ministry itself will provide free of charge. Interoperability between platforms is mandatory: if your customer uses a different platform from yours, the exchange must take place transparently. Choose the platform based on your volumes, cost per transaction, and integration with your ERP or invoicing software.
Does B2B electronic invoicing replace the SII?
No. They are two systems that coexist with different objectives. The SII (Immediate Information Supply) is an obligation to report VAT data in real time to the AEAT for companies with turnover above 6 million euros; it does not involve electronic exchange with the recipient. B2B electronic invoicing regulates the format and channel of exchange between the companies themselves. If you are already on SII, you remain on SII; additionally you will need to comply with B2B electronic invoicing within the set deadlines.