Electronic electronic invoicing B2B in Spain has evolved from a regulatory proposal into a defined, structured system with immediate operational implications for businesses. Royal Decree 238/2026, published on March 31, finally establishes the mandatory use of electronic invoicing between businesses and professionals, setting out not only the “what” but also the “how.”
For CFOs and finance leaders, this change goes beyond mere legal compliance. It involves redesigning processes, integrating systems, and adapting to a new model in which invoices and payments will be fully traceable. Let’s take a look at what’s changing, the implementation timeline, and how to start preparing now.
What does Royal Decree 238/2026 stipulate regarding B2B electronic invoicing?
The Royal Decree recently published in the Official State Gazette (BOE) sets forth the requirements for mandatory B2B electronic invoicing. These requirements had already been introduced in the Crea y Crece Act, but it now adds the basic operational elements.
Specifically, it states:
- The requirement for businesses to issue and receive electronic invoices.
- The creation of a structured exchange system.
- The need to report on the invoice statuses.
- Integration with a public platform managed by the AEAT.
- A model for mandatory interoperability between private platforms.
So we are facing a structural shift. We are no longer just talking about digitizing invoices, but about how to integrate them into a regulated and traceable ecosystem.
What has actually changed compared to the previous regulations on electronic invoices?
The truth is that the new Royal Decree published in the Official State Gazette does not change much. Rather, it clarifies and specifies several important points.
Until now, Spanish regulations have focused on:
- Requiring the issuance of electronic invoices (Crea y Crece Act)
However, there was no comprehensive system for the B2B sector. Now, the most significant changes are:
1. From a legal requirement to a full-fledged operating system
It defines a system with formats, platforms, data flows, and reporting requirements. This brings Spain closer to models such as Continuous Transaction Control (CTC).
2. All invoices go through the AEAT, either directly or indirectly
Although companies may use private platforms, they must submit a true copy of each invoice to the public solution. This will give the government visibility into B2B invoicing traffic.
3. The invoice becomes a process, not a document
The new Royal Decree introduces the requirement to report acceptance or rejection and the actual payment date within a maximum of 4 days. As a result, invoicing becomes an end-to-end monitored process.
4. Effective management of delinquent accounts
Payment must be reported to the AEAT. This will allow companies to calculate actual payment terms and detect systematic non-compliance.
5. Mandatory interoperability between platforms
The private platforms will have to interconnect with one another, accept connection requests, and not charge for doing so. As a result, technological barriers are eliminated, and there is no dependence on any single provider.
How will the new B2B electronic invoicing system work?
The model defined is a hybrid:
| Element | Function |
| Private platforms | Invoice exchange |
| AEAT Public Solution | Repository + control |
| Companies | Transmission, reception, and reporting |
Therefore, there is also a new, simplified B2B electronic invoicing process:
- Issuing electronic invoices.
- Delivery to the customer (via a private or public platform).
- Send a copy to the AEAT.
- Received by the customer.
- Status updates.
- Payment notification.
The end result of all this is that the government and the companies themselves have full traceability of the lifecycle of each invoice.
Formats and technical requirements: impact on systems and ERP
As we have previously mentioned, the Royal Decree of March 2026 on electronic invoices for B2B transactions standardizes the process and establishes clear requirements:
Supported formats:
- EDIFACT.
- CII.
Technical requirements:
- Electronic signature advanced.
- Unique identifier for each invoice.
- Ability to convert between formats.
- Secure protocols (AS2 / AS4).
- Security certification (ISO 27001).
For companies, this requires a major overhaul of their ERP and middleware systems, as well as the use of specialized solutions.
Implementation timeline: When will B2B electronic invoicing become mandatory?
The Royal Decree will be implemented gradually:
| Type of business | Deadline |
| Organizations with a turnover of over €8 million | 12 months |
| Other companies | 24 months |
The most important thing to note regarding deadlines is that the calculation begins after the pending ministerial order is issued.
Impact on financial processes: accounts payable and accounts receivable
At the same time, the change is not merely technological, as it directly affects financial processes.
- In Accounts Payable (AP), mandatory reporting of account balances and payment notifications will help ensure more accurate tracking of payment deadlines.
- In Accounts Receivable (AR) acceptance will need to be tracked, and greater visibility into collections will be provided, which will reduce disputes.
Practical example
Now, let's look at the entire process using an example. Suppose Company A (Spain) sells its product to Company B. The flow would be:
- Company A issues the invoice in UBL format.
- He sends it via a private platform.
- A copy is also sent to the AEAT.
- Company B:
- Accept the invoice.
- Record the payment due in 45 days.
- Report the payment.
In this way, the entire cycle is recorded and made available to management.
Electronic Invoicing vs. Verifactu vs. SII
On the other hand, as is always the case when discussing online invoices, it is essential not to confuse electronic invoicing with Verifactu and the SII:
| System | Scope | Objective |
| B2B Electronic Invoicing | Intercompany Transactions | Payment Tracking and Delinquency |
| IRS | VAT in near real time | Tax audit |
| Verifactu | Billing software | Fighting Fraud |
In other words, B2B electronic invoicing does not replace the SII or Verifactu. It is added to them as an additional layer of control.
What should companies do now following the Royal Decree?
For CFOs and finance teams, the top priorities are clear:
- Evaluate your current systems. You should ensure that you have an ERP system that supports structured formats and has integration capabilities.
- Review the processes. You need to analyze your invoice management, approval workflows, and payment records.
- Define a technology strategy. They should assess whether a private platform is more cost-effective or if they should opt for a public solution, and consider how integration with providers would work in each case.
- Prepare for compliance. In other words, they need to verify how reporting to the AEAT will work and ensure compliance with the standards.
Although it all stems from a requirement, this presents a great opportunity to automate processes, improve cash flow, reduce errors, and gain greater visibility.
Free webinar on how to prepare for mandatory electronic invoicing
At easyap, the on April 16, at 11:00 a.m., we will be hosting a free webinar on mandatory electronic invoicing in Spain and the changes resulting from the new Royal Decree. In it, we will cover:
- What exactly does the new Royal Decree stipulate?
- The implementation schedule.
- Its impact on financial processes.
- How to start preparing now.
- Differences between electronic invoicing, Verifactu, and the SII.
You can register for the free webinar here.
B2B electronic invoicing in Spain is entering a new phase: greater control, greater transparency, and greater operational complexity. The challenge is to comply efficiently and at scale. The question is whether your company is ready to operate in an environment where every invoice and its payment will be fully traceable. Contact us with no obligation and we’ll take a look.
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 system.
What happens if the payment isn't reported?
The Royal Decree requires that payments be reported; therefore, failure to comply may result in fines ranging from 10,000 to 50,000 euros, depending on the violation.
Does B2B electronic invoicing in Spain apply to foreign companies?
Yes, if they do business with companies established in Spain under certain conditions.
Does this replace the SII?
No. They are complementary systems with different objectives.
