Spain Approves Royal Decree for Mandatory B2B E-Invoicing

Published 30 Mar 2026
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On March 24, 2026, the Spanish Council of Ministers officially approved the Royal Decree that activates the mandatory B2B e-invoicing framework under Law 18/2022, widely known as the Crea y Crece Act. This legislative milestone sets the stage for a comprehensive digital tax transformation, combining structured e-invoicing with robust anti-fraud software requirements.

The new regulations establish a decentralized Continuous Transaction Control (CTC) model designed to increase tax transparency, combat a VAT gap estimated at €6.8 billion, and significantly reduce commercial late payments across the Spanish economy.

Implementation Timeline and Phased Rollout

The Royal Decree’s requirements do not enter into force immediately. The exact legal countdown for the Crea y Crece mandate hinges on the publication of a Ministerial Order by the Ministry of Finance, which is expected before July 1, 2026.

Once published, the B2B e-invoicing rollout will proceed in phases based on annual turnover:

Businesses with an annual turnover exceeding €8 million must comply one year after the Ministerial Order's publication (estimated July 2027).
All other businesses and self-employed professionals must comply two years after the Ministerial Order (estimated July 2028).

During the first 12 months of the mandate, obligated businesses must provide a PDF copy alongside the structured electronic invoice if the recipient is not yet legally required to receive e-invoices.

System Architecture and Exchange Platforms

Spain has opted for a decentralized, four-corner Continuous Transaction Control (CTC) model. The infrastructure is expected to align with Peppol interoperability principles. Taxpayers will have the flexibility to exchange electronic invoices through the following channels:

A free, public B2B e-invoicing application operated by the Spanish Tax Administration Agency (AEAT), which will also serve as the central invoice repository.
Privately operated, certified e-invoicing platforms.
A hybrid combination of both public and private systems.

While use of the public platform is optional, private operators must guarantee full interoperability with the state system, preserve data authenticity, and automatically share copies and status data with the central AEAT system. The government will authorize these agents based on strict criteria regarding digital security, business continuity, and interoperability.

Technical and Reporting Requirements

The public platform mandates the use of Universal Business Language (UBL) 2.1, aligning with the European EN 16931 semantic standard and preparing Spain for future VAT in the Digital Age (ViDA) reporting requirements. To ensure compliance, businesses and their software developers must adhere to specific technical criteria to transmit prescribed data to the tax authorities:

E-invoices must be structured using recognized syntax formats, specifically UBL, Facturae, CII, or EDIFACT.
Private operators must attach a unique digital signature to each invoice before transmitting it to the recipient and the tax authorities. This signature must include the issuer's tax identification number, the invoice series and number, and the date of issue.
The government plans to require the inclusion of QR codes to digitally track invoices. Additionally, tax authorities may mandate the inclusion of further transaction and payment details.
The decree introduces a mandatory reporting requirement for the lifecycle status of an invoice. Taxpayers must report the issuance, the acceptance or rejection, and the actual payment date of the invoice.

Mandate Exemptions

The mandate's scope broadly covers domestic B2B transactions, but permanent exemptions apply to:

Simplified invoices
Transactions without a statutory invoicing requirement
Cross-border invoices where either the supplier or the customer is a non-resident

The Dual Mandate Approach: Crea y Crece vs. VeriFactu

Spain’s regulatory approach is distinctive, operating on two independent but complementary mandates:

Crea y Crece (B2B E-Invoicing): This mandate necessitates the use of structured electronic invoices for all domestic B2B transactions between entities established in Spain. It effectively eliminates the use of PDFs, spreadsheets, and paper formats.
VeriFactu (Anti-Fraud Software): Running parallel to the e-invoicing requirement and anticipated to take effect in January 2027, this system mandates that billing software meets strict certification standards to ensure invoice integrity, traceability, and protection against post-issuance alterations.

Taxpayers already operating under the Immediate Supply of Information (SII) system remain exempt from VeriFactu requirements, although they must fully comply with the Crea y Crece e-invoicing obligations. Regions with independent tax regimes, such as the Basque Country and Navarre (using TicketBAI), will also maintain their distinct frameworks.

Businesses must prepare for both parallel regulatory tracks as Spain expands its digital controls ahead of the EU's planned 2028 reporting reforms.

There’s more you should know about e-invoicing in Spain – learn more about the new and upcoming regulations.