E-invoicing in Spain: the clock is already running

On 5 October 2026, Spain's Official State Gazette (BOE) published the missing ministerial order. It came into force the next day, and with it the countdown to mandatory e-invoicing between businesses and professionals began. This is not a plan for some distant future: the clock is already running.

What has happened

The obligation comes from the Ley Crea y Crece, Spain's 2022 law on business creation and growth. Royal Decree 238/2026 develops it, and Order HAC/1028/2026 puts it into practice by regulating the public e-invoicing solution of the Spanish Tax Agency (Hacienda). The Tax Agency has made it clear: 6 October 2026 is the date from which the deadlines start to count.

The dates are as follows:

• 6 October 2027 for businesses that invoiced more than €8 million in the previous year. During that first year, they will also have to send a readable PDF copy with each electronic invoice.
• Around 6 October 2028 for all other companies, self-employed workers (autónomos) and professionals: 24 months after the order came into force.

The Tax Agency's public solution must be operational at least two months before the first date. If you do not want to use it, you can work with a private platform, which will have its own obligations.

What it means for your business

This is the mistake we will see a lot in the coming months: confusing e-invoicing with VeriFactu. They are two different rules.

VeriFactu requires the software you invoice with to record each invoice in a way that cannot be altered. Under the rules currently in force, it applies to companies from 1 January 2027 and to everyone else from 1 July 2027. The specialist press has reported that the Tax Agency is considering a postponement, but until the BOE says so, those are the dates.

E-invoicing requires the invoice to travel in a structured format between your business and your customer's, and you must report its status: whether it has been accepted, rejected or paid. It is the tool the Government wants to use to tackle late payment.

Both affect you, and both depend on the same thing: your invoicing software. A spreadsheet or a word processor will not do for either of them.

There is a second consequence that hardly anyone mentions. Once all invoices circulate electronically with their status, the Tax Agency will know in real time who invoices whom and who pays late. Disorganised accounts will stop being an internal problem and become a visible one.

What your software must be able to do

Before you speak to your supplier, you should know what to ask for. Software that is ready for both rules must:

• Record each invoice so it cannot be altered, with its digital fingerprint chained to the previous one, as VeriFactu requires.
• Issue the invoice in a structured format that your customer's software can read without anyone typing anything in.
• Receive electronic invoices from your suppliers and store them in the same format.
• Report the status of each invoice: accepted, rejected or paid, and the payment date.
• Connect to the Tax Agency's public solution or to an authorised private platform.

If your software does the first three but not the last two, it will cover VeriFactu but fall short for e-invoicing.

Three mistakes we will see

Thinking it does not apply to you because you are small. The timetable only changes the date. From October 2028 the obligation reaches every company and every professional.

Waiting until the last quarter. As the date approaches, software suppliers will be overloaded, as happened with other digital obligations. Last-minute implementations cost more and come with more errors.

Buying two programs. One for VeriFactu and another for e-invoicing means duplicated data and duplicated errors. The sensible option is a single management system that does both and also keeps the accounts.

What to do now

• Check your 2026 turnover. If it is above €8 million, you have less than twelve months.
• Ask your software supplier whether their software complies with VeriFactu and whether it will issue structured electronic invoices. If they cannot give you a specific date, you have a problem.
• Review how your customers and suppliers invoice. E-invoicing works both ways: you will also have to receive them.
• Use the opportunity to get organised. Changing software at the last minute is expensive. Doing it with a year to spare is an improvement, not an emergency.

In the companies we set up, the management system is configured for VeriFactu and e-invoicing from day one. If your company already exists and you do not know whether your software will be ready in time, message us on WhatsApp and we will tell you what is missing.