On 24 March 2026, Spain’s Council of Ministers adopted the Royal Decree mandating electronic invoicing for domestic B2B transactions between companies and professionals. The decree develops Article 12 of the Ley Crea y Crece (Law 18/2022) and aligns with the EU’s ViDA initiative.
The primary policy objective is combating late payments — Spain’s average payment period stands at approximately 80 days, well above both the 60-day legal maximum and the EU average.
Key elements
The mandate covers all domestic B2B transactions where the recipient is a company or professional established in Spain; B2C transactions are excluded. The system follows a hybrid architecture with two channels: accredited private platforms, which must be freely interoperable with each other, and a free public solution operated by the AEAT. Taxpayers may use either or both, but regardless of the channel chosen, a copy of every invoice in UBL syntax must reach the AEAT public solution, which serves as both a repository and a payment-monitoring tool. Based on the latest draft, invoices must conform to the EN 16931 semantic model and be issued in one of four admitted syntaxes — CII, UBL, EDIFACT, or Facturae — with private platforms required to support transformation between all four.
Both suppliers and customers are required to electronically submit invoice status updates — including acceptance and actual payment date — to the AEAT public solution within four calendar days. This reporting obligation ensures complete traceability of the invoicing lifecycle, extending the system’s reach beyond only invoice exchange into real-time monitoring of commercial payment behaviour.
Timeline
Implementation dates are not fixed — they are triggered by a forthcoming Ministerial Order, regulating the public solution’s technical specifications, which is expected before 1 July 2026.
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~ Jul 2027 – Large companies (>€8M turnover): issuance, reception, and status reporting, 12 months after Ministerial Order
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~ Jul 2028 – All other companies: issuance and reception, 24 months after Ministerial Order
During the first 12 months, issuers must accompany e-invoices with a PDF for recipients not yet obligated.
The role of private platforms
Private platforms are the primary exchange channel for most businesses in the Spanish system. Based on the latest draft, their obligations go beyond simple invoice delivery:
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Exchange and transform invoices across all four admitted syntaxes (CII, UBL, EDIFACT, Facturae), preserving authenticity and integrity through advanced electronic signatures
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Report to the AEAT by simultaneously submitting a faithful UBL copy of every invoice to the public solution.
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Interconnect freely with any other accredited platform upon client request, using AS2 or AS4 protocols.
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Facilitate status reporting between parties and, where authorised by the recipient, communicate payment information to the AEAT public solution
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Maintain a public directory showing which businesses have designated them as their e-invoice entry point. Businesses without a declared entry point default to the AEAT public solution.
To operate within the system, platforms must be accredited — meeting requirements that include ISO/IEC 27001 certification, eIDAS-compliant signatures and seals, business continuity planning, and data governance controls.
In Spain, taxpayers already face existing obligations either under VERI*FACTU (invoicing software obligations) or the SII regime (CTC e-reporting) . Businesses enrolled in SII are exempt from VERI*FACTU requirements. As well, all supplementary regional requirements (such as TicketBAI, LROE, and others) will not be affected by the new obligations and are expected to continue operating concurrently for the foreseeable future. The newly adopted B2B e-invoicing mandate adds a separate layer of compliance on top of whichever regime applies, governing how invoices are exchanged between businesses and how their payment status is reported to the AEAT.
Sovos is actively preparing for Spain’s B2B e-invoicing mandate, building on our existing CTC compliance capabilities across multiple European jurisdictions.
For future updates on Spain and similar developments across jurisdictions, follow our Regulatory Analysis page.
