The tax authority already has a calendar for mandatory electronic invoicing between companies and professionals. Companies that bill more than eight million euros must comply from October 2027, and the rest from October 2028.
The mandatory electronic invoice now has a calendar in Spain. The tax authority has published in the Official State Bulletin the order regulating the new public tool for issuing and managing electronic invoices, and with it begins the countdown determining when companies and professionals will have to adopt it. Not everyone will reach the deadline at the same time, as the calendar depends on each business's billing volume.
An electronic invoice is, above all, an invoice. It has the same legal effects as a paper invoice and serves as proof of the delivery of goods or the provision of services. The difference lies in the format, which is digital. Within that group, it is important to distinguish between structured formats, which the recipient's programs can process automatically, and unstructured formats, such as a PDF or a scanned image, which usually require manual review or optical character recognition.
Calendar: large companies first
The obligation arises from Law 18/2022, known as the Create and Grow Law, which set two deadlines based on annual billing. Companies and professionals exceeding eight million euros per year will have to comply starting from 6 October 2027. For freelancers and small businesses, the start date will be 6 October 2028.
That the calendar is staggered does not mean that the others can wait idly. Each business must review which bracket it falls into and how much time it needs to adapt its programs, its collection processes, and how it receives invoices from its suppliers, who will also enter the system.
Only between companies and professionals
The new obligation refers to B2B operations, that is, those exchanged between entrepreneurs and professionals. Royal Decree 238/2026 links it to cases where the recipient is also an entrepreneur or professional with a registered office, permanent establishment, or residence in Spain. Therefore, an invoice issued by a freelancer to an individual falls outside the norm.
This also does not mean that all invoices from a freelancer must be electronic from those dates. The requirement applies only to those exchanged between professionals, while those issued to end consumers maintain their current rules.
What happens with the current invoicing program
Freelancers and companies will be able to continue using their usual invoicing program. The Spanish system will allow three avenues: private electronic invoicing platforms, the tax authority's public solution, or a combination of both.
Any of the options requires adherence to a common format. The invoice exchanged through the public solution must use the European semantic model EN 16931 and the UBL (Universal Business Language) syntax. Those issuing with a private platform and not using the public solution will have to send a faithful electronic copy of each invoice to the latter, also in UBL syntax.
The tax authority's free tool
Access to the public solution will be free. It is designed as an alternative for SMEs and professionals who do not want or cannot bear the cost of a private platform. The tax authority will enable a form on its electronic headquarters to generate invoices individually, and it will also allow users to consult and download invoices, faithful copies, and statuses of each one.
The adoption by SMEs is one of the main challenges of the entire process, as this group represents the most significant segment of the Spanish business fabric. The public tool aims precisely to ensure that the cost of compliance is not an obstacle for smaller businesses.
Moreover, the system will not function as a simple mailbox. The issued invoices will be immediately available to the Administration, without the need to send an additional copy. The system will generate a unique code formed by the issuer's NIF, the series and invoice number, and the date of issuance.
The recipient will also have obligations. They must communicate certain statuses of the invoice, including rejection and full effective payment. They may also inform about the dates of receipt of the goods, the service, or the invoice itself when relevant for the anti-delinquency regulations.
Mandatory electronic invoicing and VeriFactu
The mandatory electronic invoice and VeriFactu are often mentioned together, but they regulate different things. The former establishes how invoices must be issued, transmitted, and received between companies. VeriFactu, on the other hand, affects the software program with which invoices are generated, meaning that the same business may have to comply with both regulations.
What is at risk if not adapted in time
Those who do not comply on time may face penalties provided for in the General Tax Law. Additionally, there is a practical issue: an invoice that does not meet the requirements may hinder expense deduction and delay payments, as the client is not obliged to accept it. Invoices must also be kept for the legal period, which according to tax regulations is four years, and facilitate access to the Tax Agency when requested.
For SMEs and freelancers, the first step is to check what software they are currently using, whether it generates invoices in structured format, and if it can send them in UBL syntax. This review will determine how much time they need to be ready when their date arrives.
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