The e-invoicing B2B in Spain evolves from a regulatory foresight to a defined, structured system with immediate operational implications for businesses. The Royal Decree 238/2026, published on March 31, finally implements the mandatory nature of e-invoicing between businesses and professionals, establishing not only the ‘what’ but also the ‘how’.
For CFOs and financial managers, this change goes beyond legal compliance. It means redesigning processes, integrating systems, and adapting to a new model where invoice and payment traceability will be complete. Let’s see what changes, its implementation schedule, and how to prepare for it now.
What does Royal Decree 238/2026 establish regarding B2B e-invoicing?
The Royal Decree recently published in the BOE (Official State Gazette) develops the mandatory nature of B2B e-invoicing. This mandate had already been introduced in the Law Crea y Crece, but now adds the basic operational elements.
Specifically, it establishes:
- The obligation to issue and receive electronic invoices between businesses.
- The creation of a structured exchange system.
- The need to report on invoice statuses.
- Integration with a public platform managed by the AEAT.
- A model of mandatory interoperability between private platforms.
So, we are facing a structural change. We are no longer just talking about digitizing invoices, but about how they must be integrated into a regulated and traceable ecosystem.
What really changes compared to previous regulations on electronic invoicing?
The truth is that the new Royal Decree published in the BOE does not change many aspects. Rather, it clarifies and specifies several important points.
Until now, Spanish regulations focused on:
- Mandating the issuance of electronic invoices (Law Crea y Crece)
- Digitizing the relationship with the Administration (FACe, SII).
However, a comprehensive system for the B2B scope did not exist. Now, the most significant changes are:
1. From legal obligation to a complete operating system
A system is defined with formats, platforms, data flows, and reporting obligations. Something that brings Spain closer to models like Continuous Transaction Control (CTC).
2. All invoices pass through the AEAT directly or indirectly
Although companies may use private platforms, they must send a faithful copy of each invoice to the public solution. Thus, the Administration will have visibility of B2B invoicing traffic.
3. The invoice becomes a process, not a document
The new Royal Decree introduces the obligation to report on acceptance or rejection and on the effective payment date within a maximum period of 4 days. Therefore, invoicing becomes a monitored end-to-end flow.
4. Effective control of late payments
Payment must be obligatorily communicated to the AEAT. This will allow companies to calculate real payment terms and detect systematic non-compliance.
5. Mandatory interoperability between platforms
The private platforms will have to interconnect with each other, accept connection requests, and not charge for it. Consequently, technological barriers are eliminated, and dependency on any single provider is avoided.
How will the new B2B electronic invoicing system work?
The defined model is hybrid:
Therefore, there is also a new and simplified B2B electronic invoicing flow:
- Electronic invoice issuance.
- Sending to the client (via private or public platform).
- Sending a copy to AEAT.
- Reception by the client.
- Status communication.
- Payment communication.
The ultimate outcome of all this is that the Administration and businesses themselves have complete traceability of each invoice’s lifecycle.
Technical formats and requirements: impact on systems and ERP
As we have already mentioned, the Royal Decree of March 2026 on B2B electronic invoices standardizes and sets clear requirements:
Accepted formats:
Technical requirements:
- Electronic signature advanced.
- Unique identifier for each invoice.
- Ability to transform between formats.
- Secure protocols (AS2 / AS4).
- Security certification (ISO 27001).
For businesses, this entails a significant adaptation of ERP and middleware, as well as working with specialized solutions.
Implementation timeline: when will B2B e-invoicing become mandatory?
Regarding the application of the Royal Decree, it will be progressive:
The most important aspect regarding deadlines is that the calculation begins after the pending ministerial order.
Impact on financial processes: accounts payable and receivable
In turn, the change is not only technological, as it directly affects financial processes.
- In accounts payable (AP), the mandatory registration of statuses and payment communication will help achieve more precise deadline control.
- In accounts receivable (AR) acceptance tracking will be necessary, and greater visibility of collections will be offered, which will reduce disputes.
Practical example
Now, let’s look at the entire process with an example. Suppose Company A (Spain) sells its product to Company B. The flow would be:
- Company A issues the invoice in UBL.
- It sends it via a private platform.
- Concurrently, a copy is sent to AEAT.
- Company B:
- Accepts the invoice.
- Registers payment at 45 days.
- Reports the payment.
In this way, the entire cycle is recorded and available to the Administration.
Electronic Invoicing vs Verifactu vs SII
On the other hand, as always when discussing online invoices, it’s crucial not to confuse electronic invoicing with Verifactu and SII:
In other words, B2B electronic invoicing does not replace SII or Verifactu. It adds to them as an additional layer of control.
What should companies do now after the Royal Decree?
For CFOs and financial teams, the priority actions are clear:
- Evaluate their current systems. They must ensure they have an ERP ready for structured formats and with integration capabilities.
- Review processes. They need to analyze their invoice status management, approval workflows, and payment records.
- Define a technology strategy. They must assess whether a private platform is more beneficial or if resorting to the public solution is better, and how integration with suppliers would work in each case.
- Prepare for compliance. In other words, they need to check how reporting to the AEAT will be and the adaptation to standards.
Although everything stems from an obligation, this is a great opportunity to automate processes, improve cash flow, reduce errors, and gain visibility.
Free webinar on how to prepare for mandatory electronic invoicing
At easyap, on April 16, at 11:00 AM, we are organizing a free webinar on mandatory electronic invoicing in Spain and its changes after the new Royal Decree. In it, we will see:
- What the new Royal Decree exactly establishes.
- The implementation timeline.
- Its impact on financial processes.
- How to prepare starting now.
- Differences between electronic invoicing, Verifactu, and SII.
You can register for the free webinar here.
B2B e-invoicing in Spain enters a new phase: more control, more transparency, and more operational complexity. The challenge is to comply efficiently and scalably. The question is whether your company is prepared to operate in an environment where every invoice and its payment will be fully traceable. Contact us without obligation and we’ll discuss it.
Frequently Asked Questions
Is it mandatory to use the AEAT’s public platform?
No. You can use private platforms, but you must send a copy of each invoice to the public solution.
What happens if payment is not reported?
The Royal Decree mandates reporting the payment, so non-compliance may result in penalties of between 10,000 and 50,000 euros, depending on the infringement.
Does B2B e-invoicing in Spain apply to foreign companies?
Yes, if they operate with companies established in Spain under certain conditions.
Does this replace the SII?
No. They are complementary systems with different objectives.
