If you invoice other companies or freelancers in Spain, at some point in the next few years your PDF-by-email invoicing will stop being valid. That much is fact: the B2B e-invoicing obligation has been in the law since 2022 and its technical regulation is already in force. What is not fact — despite what the headlines say — is the date. And August 2026 has made the picture clearer than ever: the clock has not started ticking yet.
Here is what has been published, what is still missing, and what is actually worth doing now. No alarmism — the headlines have that covered already.
What has been published (and what hasn’t)
The framework has three pieces, and only two of them exist:
- The law. Law 18/2022, known as «Crea y Crece», requires companies and freelancers to issue and receive electronic invoices in their dealings with other businesses and professionals.
- The regulation. Royal Decree 238/2026, of 25 March, published in the BOE on 31 March and in force since 20 April 2026, defines how the system will work: formats, exchange platforms, invoice statuses and a free public solution run by the Spanish Tax Agency.
- The ministerial order. This is the piece that regulates the public solution and — here is the key point — the one that starts the countdown. The Ministry of Finance published the draft in April, with entry into force planned for 1 October 2026. The final version was expected before 1 July. As of mid-August, it has still not appeared in the BOE.
Until that order is published, no company is under any obligation yet. Any headline giving you a firm date is, at best, rounding up.
The real timeline, no hype
The regulation’s deadlines count from the day the ministerial order enters into force:
| Who | When it becomes mandatory |
|---|---|
| Companies invoicing over €8M/year | 12 months after the order |
| Everyone else, including freelancers | 24 months after the order |
If the order arrived on its planned date of 1 October 2026, large companies would be obligated on 1 October 2027 and everyone else — the vast majority of SMBs and freelancers — on 1 October 2028. Every month the order slips, the whole calendar slips with it.
Two more details from the regulation are worth knowing:
- The Tax Agency’s free public solution must be available at least two months before the first compliance date.
- During the first 12 months, large companies must attach a readable PDF to their electronic invoices, so clients that have not yet adapted are not left behind.
Careful: this is not Verifactu
It is the most common mix-up we see, and an understandable one, since both rules involve invoices and the Tax Agency. But they are different obligations with different dates:
- Verifactu regulates the software you invoice with: your program will have to produce tamper-proof records that can be reported to the Tax Agency. Its dates are already fixed: 1 January 2027 for companies and 1 July 2027 for the self-employed.
- B2B e-invoicing regulates the exchange: how the invoice reaches your client and how its status gets reported — accepted, rejected, paid. Its calendar depends on the ministerial order that is still pending.
The practical consequence is awkward but real: Verifactu arrives first. If you are going to touch your invoicing system to comply with Verifactu in 2027 — and if you run a company, you should be on it already — that is the perfect moment to pick a solution that is also ready for B2B e-invoicing. Make the change once, not twice.
What actually changes in your day-to-day
When the obligation lands, it will not just be a format change. The system is designed to fight late payments, and that means traceability: your invoices will travel through certified platforms or the public solution, and your clients will have to report their statuses — accepted, rejected, paid — within set deadlines. The date you actually get paid will stop being invisible.
For an SMB that gets paid late, this is good news. For an SMB that pays late, it is a warning with years of advance notice.
What to do now (and what can wait)
You do not need to buy anything tomorrow or believe dates that do not exist yet. What is worth doing, in this order:
- Sort out Verifactu first. It is the obligation with a firm, nearer date. If your invoicing software has no clear plan for January 2027, ask your provider this week.
- Choose with e-invoicing in mind. When evaluating any invoicing tool, ask whether it supports (or will support) B2B exchange under Royal Decree 238/2026. You will avoid paying for two migrations.
- Review how you collect and pay. Status traceability will expose real payment terms. Knowing today how long you take to get paid — and to pay — gives you room to fix it without pressure.
- Ignore the noise. Until the ministerial order is in the BOE, any specific date is an estimate. We will update this article when it is published.
At SamApps we help SMBs get their invoicing up to standard: from automation and integrations that connect invoicing with the rest of your business to adapting for Verifactu and what comes after it. If you are not sure where your company stands, tell us about your case and we will tell you what you need to do and what you don’t — even if the answer is «nothing yet».