# Spain's B2B e-invoicing: Ley Crea y Crece

Spain's Law 18/2022 (Ley Crea y Crece) makes every invoice between businesses and professionals electronic. Royal Decree 238/2026 sets the rules: invoices travel as structured data in Facturae, UBL, CII or EDIFACT, and a PDF by email no longer counts as the invoice. You also report when an invoice is paid in full, so late payment shows up. The tax agency (AEAT) offers a free public tool to issue invoices, and Order HAC/1028/2026 started the countdown on 6 October 2026.

## Who

It covers businesses and autónomos invoicing other businesses or professionals. Companies with more than 8 million euros in turnover are expected to start 12 months after 6 October 2026, and everyone else 24 months after. Sales to consumers and simplified invoices (tickets) stay outside, unless the ticket is a qualified one. The AEAT has not published exact start days on the pages we checked.

## Dates

- 2022-09-29: Law 18/2022 (Ley Crea y Crece) is published and its article 12 makes e-invoicing between businesses mandatory, pending a regulation.
- 2026-03-31: Royal Decree 238/2026 sets the technical rules and is published in the BOE. It takes effect on 20 April 2026, but the obligations wait for a ministerial order.
- 2026-10-06: Order HAC/1028/2026 on the tax agency's free invoicing tool takes effect, the day after it appeared in the BOE. The 12 and 24 month countdowns start.
- 2027-10: Expected start for businesses with more than 8 million euros in turnover: 12 months after the order took effect.
- 2028-10: Expected start for every other business and autónomo: 24 months after the order took effect.

## Tools

- TS Facturas: partial. Lists Facturae, UBL, CII and EDIFACT, and says it will update to the B2B rules, including acceptance and payment statuses. (https://www.billin.net/factura-electronica-obligatoria/, 2026-10-05)
- Anfix: partial. Issues signed Facturae invoices and shows whether your client received them. Its page still quotes older B2B dates. (https://www.anfix.com/facturacion/factura-electronica, 2026-10-05)
- Contasimple: partial. Creates Facturae invoices for public bodies and sends them to FACe. It says the software updates itself as the B2B rules arrive. (https://www.contasimple.com/funcionalidades/FacturaE, 2026-10-05)
- Holded: partial. Exports Facturae XML for public bodies, but you sign it outside Holded and upload it yourself. Its help page does not cover B2B yet. (https://help.holded.com/en/articles/6967114-create-and-manage-an-e-invoice, 2026-10-05)

## Questions

### Can I keep sending PDF invoices by email?

Until your start date, yes. After it, the invoice itself has to be a structured file in Facturae, UBL, CII or EDIFACT. For their first 12 months, companies above 8 million euros must also attach a readable PDF unless the client accepts the original format. A PDF on its own stops being a valid B2B invoice.

### Do I have to pay for software?

No. The decree says access to the AEAT's public invoicing tool is free, and the AEAT must open it at least two months before the first obligations apply. It works in UBL and can exchange invoices with private platforms. Many autónomos will still prefer their usual invoicing app, as long as it connects to the new system.

### What is the payment status I have to report?

When you receive an invoice, you tell the issuer if you accept or reject it and when you pay it in full. Article 12 of the decree gives you up to 4 calendar days from the payment date, not counting weekends and national holidays. Autónomos and businesses under 8 million euros get an extra 12 months before these status duties apply. The goal is to show who pays late.

### Is this the same as VeriFactu?

No, they are two separate rules that you will have to follow at the same time. VeriFactu controls the software that records your invoices and can send each record to the AEAT. B2B e-invoicing controls the format and delivery of the invoice to your client, plus the payment status. A good invoicing app should handle both, so ask your provider about each one.

### Do I need this if I only sell to consumers?

No. The obligation covers invoices between businesses and professionals, so sales to private customers are outside it. Simplified invoices, the tickets you give at a till, are excluded too, except qualified ones. If you sell to a mix of consumers and companies, only the invoices to companies and autónomos change.

## Sources

- [BOE: Ley 18/2022, de creación y crecimiento de empresas (texto consolidado)](https://www.boe.es/buscar/act.php?id=BOE-A-2022-15818)
- [BOE: Real Decreto 238/2026, sistema de facturación electrónica obligatoria entre empresarios y profesionales](https://www.boe.es/buscar/act.php?id=BOE-A-2026-7295)
- [BOE: Orden HAC/1028/2026, solución pública de facturación electrónica](https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-20587)
- [Agencia Tributaria: Facturación electrónica obligatoria (nota de 31 de marzo de 2026)](https://sede.agenciatributaria.gob.es/Sede/todas-noticias/2026/marzo/31/facturacion-electronica-obligatoria.html)