Spain to Introduce Mandatory B2B E-Invoicing by Second Half of 2026
Spain has moved closer towards modernizing its invoicing system with the long-awaited implementation of mandatory B2B electronic invoicing. A final draft of the “Ley Crea y Crece Ordinance” has now been published on the Ministry of Economy, Commerce and Enterprise’s website, opening a public consultation period until April 7, 2025.
This legislative move is part of a broader push to increase business transparency, reduce fraud, and streamline tax compliance. Here’s a breakdown of what the final draft entails and what it means for businesses operating in Spain.
What’s in the final draft?
Compared to the version submitted to the European Commission back in January 2024, this latest draft introduces some notable updates, particularly around technical standards and implementation timelines:
- Mandatory UBL syntax: All e-invoices transmitted via the public e-invoicing solution must use UBL (Universal Business Language) syntax. This requirement also applies to invoice copies submitted to the public platform when a private e-invoicing system is used.
- Staggered implementation timeline:
- Large companies (with annual turnover exceeding €8 million) will be required to comply one year after the Ministerial Order is published in the Official Gazette.
- All other companies will have two years from that date to comply.
- This means mandatory e-invoicing is unlikely to begin before the second half of 2026.
- Large companies (with annual turnover exceeding €8 million) will be required to comply one year after the Ministerial Order is published in the Official Gazette.
Who will be affected?
The Ordinance will apply only to B2B local transactions, meaning:
- E-invoicing will not be mandatory when the customer is a business not established in Spain or lacking a permanent business site in the country.
- Non-resident companies will only be subject to e-invoicing obligations if their local B2B transactions are carried out through a permanent establishment in Spain for indirect tax purposes.
Invoicing software requirements
Alongside e-invoicing, the Spanish government is also introducing the use of approved invoicing software in accordance with Royal Decree 1007/2023, widely known as the “Veri*factu Ordinance.”
Initially, companies under this rule were expected to comply by July 1, 2025. However, delays in publishing the accompanying technical specifications (Ministerial Order HAC/1177/2024) have led to a proposed amendment. As a result, the Veri*factu software compliance deadline is also expected to shift to 2026.
What’s next?
Following the close of the public consultation period on April 7, 2025, the Ordinance must still be approved by Spain’s Council of Ministers and formally published in the Official State Gazette. After that, a separate Ministerial Order will outline the specifics of the public e-invoicing solution.
This staggered but definitive rollout gives companies time to adapt—but preparation should begin now. Ensuring invoicing systems are both UBL-compatible and compliant with Veri*factu standards will be key to avoiding disruptions when the new rules take effect.
