If you have heard about “mandatory e-invoicing” and about “Verifactu” and are not sure whether they are the same thing, you are not alone: they get mixed up constantly. They are two different obligations, with different timelines, and both affect how you issue and receive invoices. This guide separates them, summarises the deadlines and suggests what to prepare calmly before they arrive.
We are not an accountancy firm and we do not give tax advice. This guide summarises rules published up to 6 October 2026 and we have checked them against the official sources linked at the end, but you should confirm your own situation with your accountant or adviser.
Two different obligations
| E-invoicing between businesses | Verifactu (invoicing systems) | |
|---|---|---|
| What it regulates | The format and exchange of invoices between businesses and professionals | The software used to issue invoices and the records it keeps |
| What it requires | Invoices in a structured format, sent through private platforms or the public solution | Software that guarantees the integrity, traceability and inalterability of invoicing records |
| Legal basis | Law 18/2022 (the “Crea y Crece” law) and Royal Decree 238/2026 | Royal Decree 1007/2023, amended by Royal Decree-Law 15/2025 |
An invoice can comply with one and not the other. That is why it is worth asking your accountant about both.
E-invoicing between businesses: timeline
Royal Decree 238/2026 of 25 March develops the obligation to invoice electronically between businesses and professionals. The key points:
- Structured format. An email with a PDF attached will no longer be enough. The royal decree provides for structured syntaxes such as UBL, CII, EDIFACT or Facturae. For those invoicing over €8 million there is a 12-month transitional period in which a PDF can accompany the invoice, but it does not replace the structured format.
- Two channels. Private invoice-exchange platforms, the Tax Agency’s public e-invoicing solution, or a combination of both.
- Deadlines. They run from the entry into force of the ministerial order regulating the public solution, Order HAC/1028/2026 of 2 October, published in the Spanish official gazette (BOE) on 5 October 2026. The obligation applies 12 months later for those invoicing over €8 million and 24 months later for all other businesses and professionals. That puts the dates at around October 2027 and October 2028 respectively.
If you invoice less than €8 million, you have in principle until the end of 2028. That does not mean you can ignore it: your larger customers and suppliers will start working with e-invoices earlier and are likely to ask you to adapt.
Verifactu: timeline
Royal Decree-Law 15/2025 postponed the adaptation of invoicing software systems. According to the Tax Agency’s information note, the dates are:
- 1 January 2027 for corporate income tax payers.
- 1 July 2027 for all other obliged parties, including the self-employed and professionals.
Until those dates there is a transition period. Software manufacturers, however, have been obliged since 2025 to offer adapted programs. There are exceptions and special regimes (for example, the foral territories), so confirm with your accountant which one applies to you.
What you can prepare now
None of this requires rushing, but it is best not to leave it to the last quarter:
- Ask your accountant which obligations apply to you and when. It is the most important conversation.
- Check your invoicing software. Ask its vendor whether it will be compatible with Verifactu and with sending structured e-invoices, and by what date.
- Tidy up your master data. Legal name, tax ID and billing email for customers and suppliers, correct and up to date. It causes more errors than anything else.
- Review your numbering and series. Sequential numbering without gaps makes everything else easier.
- Stop relying on PDFs by email. Start centralising the inflow and outflow of invoices in a single place (a mailbox, a platform) instead of scattered conversations.
- Measure how much time you spend on invoicing today. If it already overwhelms you, the change of format is the moment to organise it, not to add more workload.
Where a service like ours fits
We do not replace your accountant and we do not issue invoices for you from software of our own. What we do is the work before and after: collecting and organising invoices, extracting their data, reconciling payments and receipts and leaving the month-end close prepared, with a person reviewing every delivery. When the change of format arrives, having that process already in order makes it much easier. If you would like to see how it is set up, there is the step-by-step guide to automating invoice management and the invoice and administration management service.
Official sources
- Royal Decree 238/2026 of 25 March (BOE), developing mandatory e-invoicing between businesses and professionals.
- Order HAC/1028/2026 of 2 October (BOE), regulating the public e-invoicing solution.
- Tax Agency information note on the extension of the deadline to adapt invoicing software systems.