New B2B electronic invoicing obligations in Spain

New B2B electronic invoicing obligation in Spain

We would like to inform you of the recent publication in the Spanish Official Gazette (BOE) of Royal Decree 238/2026, dated 31 March 2026, which regulates mandatory electronic invoicing between businesses and professionals (B2B) in Spain.

This regulation applies to:

– Businesses and professionals established in Spain.

– Non-resident entities operating in Spain through a permanent establishment.

It affects transactions carried out between businesses and professionals (B2B). As a general rule, transactions with final consumers (B2C) and simplified invoices fall outside the scope of the regulation, except for certain specific cases provided for therein.

This regulation establishes the obligation to issue and receive electronic invoices in a structured format, as well as the obligation to report on their status (acceptance, rejection, and effective payment). This model goes beyond mere invoice digitalisation, introducing a system to monitor the entire invoice lifecycle through to payment.

In this regard, it is worth noting that:

– Invoices must be issued in a structured format that allows automated processing (standards such as UBL, CII, EDIFACT, or Factuarae are accepted).

– Simple PDF will not be considered valid electronic invoices for compliance purposes, although they may be retained as a visual representation.

The system is structured through interoperable private platforms and a public solution managed by the Spanish Tax Agency. Although companies may operate through private providers, it is important to note that:

– Invoices must be integrated in the public system (by sending a copy when the public solution is not used directly).

– The public solution acts as both a repository of invoices and an exchange mechanism, particularly where platforms are not interconnected.

– The recipient must report rejection or full payment of invoices to the public solution.

– Information must be submitted within short timeframes (maximum of 4 calendar days, excluding weekends and national holidays).

Consequently, there is no full private circuit, but rather a model in which the Administration becomes part of the information flow.

Compared to earlier versions of the draft regulation, the final text provides greater clarity on key aspects, particularly regarding the role of the public solution (now a structural element of the system), the obligations to report invoice statuses and payments, and the interoperability requirements between platforms.

The effective application of the obligation will depend on a Ministerial Order pending publication. From that moment, the adaptation periods will be 12 months for companies with turnover exceeding €8 million and 24 months for all others.

Given the impact on internal systems and processes (invoicing, procurement, accounting, and treasury), we recommend initiating an assessment as soon as possible to evaluate:

– The level of readiness of current systems

– The need for integration with exchange platforms

– The impact on collections and payment management processes

We remain at your disposal to assess the specific impact on your organization and to define an appropriate adaptation plan. We will also provide further information through dedicated webinars and will be available to address any questions or concerns.