Spain's e-invoicing mandate

What it is

Law 18/2022 (“Crea y Crece”) requires invoices between businesses and professionals to be genuinely electronic: a structured file software can read with nobody retyping it, not a PDF by email. Royal Decree 238/2026 develops it, and Order HAC/1028/2026, published in the official gazette on 5 October 2026, starts the clock.

On top of sending it, the client has to tell the tax agency whether they accept or reject it and when they pay it: the law's aim is to measure and shorten payment times.

The dates

6 October 2027

Businesses and professionals with turnover above €8 million: issue, receive and report statuses and payments.

6 October 2028

Everyone else, freelancers included: issue and receive e-invoices (and companies, report statuses and payments).

6 October 2029

Individuals (autónomos) and pass-through entities: report statuses and payments.

All three dates count from the order's entry into force on 6 October 2026, according to the tax agency (AEAT).

Who it affects, and who it doesn't

• Invoices between businesses and professionals based in Spain: to a company, to another freelancer.
• Not invoices to private individuals, which stay as they are.
• Nor clients abroad: the obligation is for recipients in Spain.

How it's sent

There are two routes, which can be combined: a private e-invoice exchange platform (your software's, for instance) or the AEAT's public solution, free and designed for small businesses and professionals, which will also have a form to create invoices by hand.

The public solution uses the European EN 16931 model in UBL syntax. If you issue through a private platform, it also sends the tax agency a faithful copy of each invoice in UBL. The public solution keeps a copy of all of them.

It isn't Verifactu

Two different obligations that often get mixed up. Verifactu (from 1 January 2027 for companies and 1 July 2027 for freelancers) is about how your software records every invoice you issue, whoever it goes to. E-invoicing is about the format it reaches your business client in. Both apply to you.

What to do now

• Nothing urgent if you're under €8 million: you have until 6 October 2028.
• Ask your invoicing software how and when it will handle it.
• Make sure your business clients' and suppliers' tax details are complete: with e-invoicing, a wrong tax ID won't get through.
• Verifactu first: it arrives sooner and applies to everyone invoicing with software.

And Nyrut

Today Nyrut issues invoices as PDF and with a link, which is fine until the obligation reaches you, and has Verifactu built for when it's your turn. UBL e-invoices it doesn't do yet: we'll have them ready before they're mandatory for freelancers and small businesses, and we'll say so here.

This is a guide to help you understand it, not tax advice: check your own case with your accountant (gestoría).