Mandatory e-invoicing in Spain: what changes for accounts payable

Spain’s Law 18/2022 on business creation and growth (known as «Crea y Crece») established that all companies and self-employed professionals will have to issue and receive electronic invoices in transactions between them. The implementing rules came with Royal Decree 238/2026 of 25 March, published in the Official State Gazette (BOE) on 31 March 2026.

Timeline

The deadlines don’t run from the Royal Decree itself, but from the ministerial order regulating the Tax Agency’s public e-invoicing solution. That order was published in the Official State Gazette on 5 October 2026 (BOE-A-2026-20587), so the timeline now has dates:

• Companies with turnover above €8 million: mandatory from 6 October 2027.
• All other companies and professionals: mandatory from 6 October 2028.

For the following 12 months, companies above €8 million must send a PDF alongside the e-invoice unless the recipient agrees otherwise. And self-employed individuals and pass-through entities below that threshold get a further 12 months during which reporting invoice statuses is voluntary. For a company above €8 million, that leaves less than a year to have the receiving, approval and status-reporting process ready.

What the recipient has to do

For accounts payable, the biggest change isn’t the format but the invoice statuses. The recipient has to report:

• The commercial acceptance or rejection of the invoice, with its date.
• Full effective payment, with the actual payment date.

These must be reported within four business days. The aim is to measure late payment: the authorities will know when each invoice was accepted and when it was actually paid. That requires an approval and payment process with reliable dates, not a folder of pending PDFs.

Formats

Invoices will have to be issued in structured formats. The public solution works with UBL, and other standard formats are accepted between private platforms. For the receiving team, this means more and more invoices will arrive as data, not as images.

What about Verifactu? It’s not the same

Verifactu concerns the software used to issue invoices and their registration with the Tax Agency. After Royal Decree-law 15/2025, it applies to companies from 1 January 2027 and to other taxpayers from 1 July 2027. Mandatory e-invoicing, by contrast, governs exchange between businesses and directly affects the recipient.

What e-invoicing doesn’t solve

A structured invoice saves you reading the data, but not the core work of accounts payable:

• It still has to be matched to the purchase order and delivery note: correctly read data doesn’t mean the amount is right.
• You still have to catch duplicates: the same invoice can arrive through several channels.
• It has to be approved or rejected in time to report its status by the deadline.
• And for years, structured invoices will coexist with PDFs from small or foreign suppliers.

Checklist for the accounts payable team

1. Check your turnover to know which phase applies to you.
2. Ask your ERP provider how it will receive and post structured invoices.
3. Decide who accepts or rejects each invoice, and how quickly.
4. Make sure the actual payment date is recorded and easy to report.
5. Review your duplicate controls and your matching against order and delivery note.
6. Plan the workflow for suppliers who will keep sending PDFs.

This guide summarises the regulation for information purposes and is not legal or tax advice. See the official text of Royal Decree 238/2026 in the BOE and the Spanish Tax Agency’s website.