Mandatory B2B e-invoicing: deadlines and requirements

Which rules govern it

• Ley 18/2022, on business creation and growth (“Crea y Crece”). Its article 12 amended Ley 56/2007 so that businesses and professionals issue, send and receive electronic invoices in their commercial dealings with each other.
• Real Decreto 238/2026, of 25 March (BOE of 31 March 2026). This is the regulation itself: formats, exchange, invoice statuses and timetable. It came into force twenty days after publication, but its obligations apply according to the deadlines explained below.
• Orden HAC/1028/2026, of 2 October (BOE of 5 October 2026). It regulates the AEAT’s public e-invoicing solution. It came into force on 6 October 2026, and the deadlines started counting from then.

Deadlines according to your turnover

The fourth final provision of Real Decreto 238/2026 counts the deadlines from the entry into force of the ministerial order:

Transitional rules

• During the first twelve months, those with a turnover above 8 million euros must send a PDF copy along with their electronic invoices, unless the recipient agrees to receive them only in the original format.
• Individuals and income-attribution entities with a turnover of no more than 8 million euros may report the status of their invoices voluntarily during the twelve months following their start date.

Accepted formats and the public solution

The invoice must follow the semantic data model of the European standard EN 16931, using one of these syntaxes: UBL, CII, the EDIFACT invoice message or the Facturae format. The preamble of the royal decree also mentions Peppol BIS.

Invoices can be exchanged through private platforms or through the AEAT’s public e-invoicing solution. Anyone who does not issue through the public solution must send it a true copy of each invoice in UBL syntax. Access to the public solution is free, and the AEAT will provide a free app or form for issuing invoices; the order provides for the solution to be available at least two months before the obligation first takes effect.

Differences from Verifactu

The Ministry of Finance has announced that it wants to align both timetables. We explain this in Verifactu postponed to 2028 and in what Verifactu is.

What Facturae is and where it fits

Facturae is the Spanish XML e-invoice format, already used for invoicing public authorities through FACe. Real Decreto 238/2026 accepts it as one of the valid syntaxes for business-to-business invoices.

What zBilling does today

• Facturae for public authorities: you download the Facturae XML of any invoice (enable it under Customization › Program settings). zBilling does not sign or send it: to submit it through FACe, sign it with your digital certificate.
• Verifactu: records with a chained hash, QR code and submission to the AEAT with your digital certificate.
• PDF invoices with your own design, sending by email and tracking.

Checklist to get ready

1. Work out your turnover for the previous year: decide whether the 12- or 24-month deadline applies to you.
2. Check whether your business customers already receive electronic invoices, and through which channel.
3. Keep your customers’ tax details up to date (NIF tax ID, company name, address): without them there is no valid electronic invoice.
4. Ask your invoicing software provider how and when it will issue in EN 16931 format and how it will send the copy to the public solution.
5. Get Verifactu sorted first: records and invoices will be the foundation for everything else.

Frequently asked questions

Official sources

• Real Decreto 238/2026, of 25 March, on e-invoicing between businesses and professionals (BOE of 31 March 2026)
• Orden HAC/1028/2026, of 2 October, regulating the public e-invoicing solution (BOE of 5 October 2026)
• Ministry of Finance — Information note of 5 October 2026: planned change to the deadlines of Real Decreto 1007/2023
• Real Decreto 1007/2023, of 5 December: Regulation on computerised invoicing systems (consolidated text)