Published on September 1, 2026 · The mitza.es team
It's common to run into businesses that assume VeriFactu and B2B e-invoicing are the same obligation, simply because both involve invoicing and both have been on advisors' and accountants' lips for months. They're not. They're two independent regulations, with different goals and their own timelines, and it's worth keeping them straight because both will affect nearly every SME and freelancer in Spain over the next few years.
What Ley Crea y Crece actually requires
Spain's 2022 Ley Crea y Crece introduced the obligation to exchange electronic invoices between companies and self-employed professionals (B2B). What had been pending for years was its technical implementing regulation: in March 2026, Real Decreto 238/2026 was published, spelling out how that obligation applies in practice. It requires invoices exchanged between businesses and freelancers to use structured, machine-readable electronic formats: Facturae, EDIFACT, UBL or CII. A plain PDF attached to an email is no longer sufficient as the sole invoice format; the stated goal is interoperability between private invoicing platforms and the Spanish Tax Agency's central repository.
During the transition period, electronic invoices can still be accompanied by a PDF version for recipients who aren't yet technically adapted, so this isn't an overnight change without any room to adjust.
The rollout calendar by company size (and why it doesn't have a fixed date yet)
RD 238/2026 sets out a staggered rollout based on each company's annual turnover, with one important nuance: the countdown doesn't start from the publication of the Royal Decree itself, but from the ministerial order that formally activates the public e-invoicing solution/platform. Once that order takes effect:
- Companies and professionals with more than €8 million in annual turnover will have 12 months to comply.
- All other businesses — SMEs, freelancers and sole proprietors — will have 24 months to comply.
As of September 2026, that ministerial order still hasn't been published, so the exact starting point of the calendar remains pending. Trade press estimates suggest the practical effect would land around October 2027 for large companies and October 2028 for everyone else, but those should be treated as press projections about a timeline that hasn't been activated yet, not as official dates fixed in the regulation.
How this differs from VeriFactu
The confusion with VeriFactu is understandable but avoidable. VeriFactu, part of Spain's Anti-Fraud Law and already delayed to 2027, as we explain in detail here, regulates how your invoicing software must behave toward the tax authority: records can't be manipulated, hidden or duplicated. B2B e-invoicing under Ley Crea y Crece regulates something different: the format in which one company sends an invoice to another, so it's structured and interoperable instead of a standalone PDF. These are parallel obligations — each with its own timeline, and both still with dates pending confirmation at some stage — and you'll need to comply with both once they take effect.
What you can do now, even without a fixed date
The fact that the ministerial order hasn't been published yet isn't a reason to wait and do nothing: the 12- and 24-month windows are short if you need to change software or renegotiate processes with suppliers and clients. It's worth getting ahead of several fronts now:
- Check whether your invoicing software or accountant already supports, or plans to support, Facturae, EDIFACT, UBL or CII.
- Review with your main B2B suppliers and clients what format they're invoicing in today and whether they're aware of the change coming.
- Don't treat October 2027 or October 2028 as a confirmed final date until the ministerial order is actually published.
- Use this window to get other pending digital obligations in order too, such as mandatory digital time tracking or the Kit Digital 2026 deadlines.
If you want a review of how ready your website and digital systems are before the calendar activates, you can request an audit from us and work with breathing room instead of a last-minute scramble.