Mandatory e-invoicing in Spain: dates and Verifactu

Mandatory e-invoicing is the obligation for invoices between businesses and professionals to be issued, sent and received in a structured electronic format, and for the recipient to report whether it accepts or rejects them and when it pays them. It is set by article 12 of Law 18/2022 (the business creation and growth law), and its regulation, Royal Decree 238/2026, has already been approved and published in the BOE.

The dates are published by the Spanish tax agency: 6 October 2027 for businesses and professionals whose turnover exceeded 8 million euros in the previous year, and 6 October 2028 for everyone else. Verifactu is a different rule: it governs the program you invoice with, not the format of the invoice or how it is exchanged.

This is not legal or tax advice. Confirm your case, your date and your obligations with your accountant.

The obligation stems from Law 18/2022 of 28 September on the creation and growth of companies. Its article 12 amends article 2 bis of Law 56/2007 so that all businesses and professionals issue, send and receive electronic invoices in their commercial dealings with other businesses and professionals. In other words: it covers transactions between companies and the self-employed, not sales to consumers.

The law itself left the obligation waiting for a regulation: it takes effect one year after that regulation is approved for those invoicing more than 8 million euros a year, and two years after for everyone else (eighth final provision). That is why for three years there was no date: the regulation was missing.

An electronic invoice, in the sense of this rule, is not a PDF sent by email. It is a structured file that another program can read without anyone retyping it, and it travels through a private exchange platform or through the public solution run by the tax agency.

Royal Decree 238/2026 of 25 March was published in the BOE on 31 March 2026 and entered into force twenty days later. It did not set a direct date: its deadlines run from the entry into force of the ministerial order that regulates the public solution (fourth final provision). That order is Order HAC/1028/2026 of 2 October, published in the BOE on 5 October 2026 and in force since 6 October 2026, so the clock runs from that day: twelve months for large businesses and twenty-four for everyone else.

The regulation also governs invoice statuses (article 10): the recipient has to report commercial acceptance or rejection and its date, and full effective payment and its date. And it tasks the tax agency with a free public e-invoicing solution for issuing, receiving and reporting statuses (article 11). Invoices that go through that solution follow the European EN16931 model with UBL syntax (article 3 of the order). These sources were last checked on 22 October 2026.

Issuing and receiving e-invoices: over 8 million euros

Businesses and professionals whose turnover exceeded 8 million euros in the previous calendar year. From 6 October 2027.

Issuing and receiving e-invoices: everyone else

All other businesses and professionals, the self-employed included. From 6 October 2028.

Reporting statuses and payments: legal entities

From 6 October 2027 if they exceed 8 million euros; from 6 October 2028 for all other legal entities.

Reporting statuses and payments: individuals

Self-employed people and entities under the income attribution regime below the threshold: from 6 October 2029. Voluntary until then.

Both rules touch invoicing, which is why they get confused, but they regulate different things and have different dates. Verifactu is the usual name for the regulation on requirements for invoicing computer systems (Royal Decree 1007/2023): it requires the program you invoice with to generate records that cannot be altered without leaving a trace. Mandatory e-invoicing governs the format of invoices between businesses, how they are exchanged and how their statuses are reported.

A program can comply with Verifactu and still not work for mandatory e-invoicing, and the other way round. When you ask your supplier, ask about the two things separately.

What it regulates

Verifactu: the program you invoice with (records, fingerprint, retention). Mandatory e-invoicing: the format of invoices between businesses, their delivery and their statuses.

Which rule

Verifactu: Royal Decree 1007/2023. Mandatory e-invoicing: Law 18/2022, Royal Decree 238/2026 and Order HAC/1028/2026.

Which transactions

Verifactu: every invoice issued by someone subject to it, those to consumers included, except the exclusions in the regulation (for example, those who keep their VAT records through the Immediate Supply of Information, SII). Mandatory e-invoicing: only transactions between businesses and professionals.

From when

Verifactu: legal dates in 2027 (Royal Decree-law 15/2025), with a postponement to 2028 announced and pending publication in the BOE. Mandatory e-invoicing: 6 October 2027 and 6 October 2028.

You do not need to change program this month. The date for most small businesses is 6 October 2028, and the regulation requires the tax agency’s public solution to be available at least two months before the obligation first applies (fifth additional provision). Changing out of fear of the deadline is the most expensive decision: you buy a program in a hurry that then has to be changed again.

Nor do you need to treat Verifactu and e-invoicing as a single project. They are two adaptations with two calendars; what does matter is that the program you choose, or the one you already have, can comply with both when the time comes.

• Note the date that applies to you according to your turnover and confirm it with your accountant.
• Ask your supplier, in writing, whether their program will issue and receive invoices in the format the regulation requires and whether it will report statuses.
• If you invoice consumers, remember that those invoices are outside mandatory e-invoicing, although they are inside Verifactu if you are subject to it.
• If you issue few invoices to other businesses, the free public solution may be enough: wait to see it before contracting anything.

The obligation applies to you just the same, as a user. A custom system has one advantage and one risk: the advantage is that it adapts to whatever the regulation asks without waiting for a vendor; the risk is that, if nobody maintains it, nobody will adapt it. The first thing is to know who answers for that system today.

This guide is informative and does not propose adapting any system. If you want to know what to look at in a program built by another company, the Verifactu guide covers it; if what you are considering is replacing spreadsheets with a system that invoices, the guide on automating invoices from Excel explains the routes.

More about custom software

What it is, when it pays off and what is delivered

Verifactu in the Canary Islands

The 2027 dates, IGIC and the announced postponement

Official text in the Spanish Official State Gazette (BOE) and the calendar published by the Spanish tax agency. This guide was written on 22 October 2026 with the rules in force that day; if they change, the update date above will say so. Remember that it is not legal advice.

The obligation

Law 18/2022 of 28 September on the creation and growth of companies, article 12 (BOE-A-2022-15818) (opens in a new tab)

The regulation

Royal Decree 238/2026 of 25 March developing the mandatory e-invoicing system between businesses and professionals (BOE-A-2026-7295) (opens in a new tab)

The order that starts the clock

Order HAC/1028/2026 of 2 October regulating the public e-invoicing solution (BOE-A-2026-20587) (opens in a new tab)

The dates

E-invoicing implementation calendar, Spanish tax agency website (opens in a new tab)

Verifactu

Royal Decree 1007/2023 of 5 December (BOE-A-2023-24840) (opens in a new tab)

What is mandatory e-invoicing?

It is the obligation, set by article 12 of Law 18/2022, for invoices between businesses and professionals to be issued, sent and received in a structured electronic format, and for the recipient to report whether it accepts or rejects them and when it pays them. It is developed by Royal Decree 238/2026. It does not cover invoices to consumers.

When does e-invoicing become mandatory?

According to the tax agency’s calendar: from 6 October 2027 for businesses and professionals whose turnover exceeded 8 million euros in the previous year, and from 6 October 2028 for everyone else, the self-employed included. The deadlines run from the entry into force of Order HAC/1028/2026. Confirm your date with your accountant.

Has the e-invoicing regulation been approved?

Yes. It is Royal Decree 238/2026 of 25 March, published in the BOE on 31 March 2026. The ministerial order regulating the public solution, on which the deadlines depended, Order HAC/1028/2026, was published on 5 October 2026 and has been in force since 6 October 2026. As of 22 October 2026 we have found no later rule changing those dates.

Are mandatory e-invoicing and Verifactu the same thing?

No. Verifactu (Royal Decree 1007/2023) governs the program you invoice with: records that cannot be altered without leaving a trace. Mandatory e-invoicing (Law 18/2022 and Royal Decree 238/2026) governs the format of invoices between businesses, their exchange and the reporting of their statuses. They have different dates, and a program can comply with one and not the other.

Is there a free tool for issuing electronic invoices?

Yes. The regulation tasks the tax agency with a public e-invoicing solution, free to use, for issuing and receiving invoices and reporting their statuses. Order HAC/1028/2026 regulates it, and both the regulation and the order require it to be available at least two months before the first date on which the obligation applies. If you issue few invoices to other businesses, it may be enough for you.

Do I have to change my invoicing program because of e-invoicing?

Not necessarily, and it is best not to decide out of fear of the deadline. Ask your supplier, in writing, whether their program will issue and receive invoices in the format the regulation requires and will report statuses; if it is custom-built, find out who maintains it. Confirm with your accountant which date applies to you.

Verifactu in the Canaries: 2027 dates and delay

Verifactu in the Canaries: whether it applies, how it affects IGIC, the 2027 dates in force and the delay announced for 2028. Royal Decree 1007/2023.

Automate invoices from Excel: four routes

How to stop typing the same invoice twice: four routes from Excel, when each one fits and what to check first for Verifactu and the IGIC.