New Royal Decree on Mandatory Electronic Invoicing Between Companies: What It Establishes

On 31 March 2026, Royal Decree 238/2026 of 25 March was published in the Spanish Official State Gazette (BOE), establishing the mandatory electronic invoicing system for businesses and professionals in Spain.

The regulation specifies how the electronic invoicing system will operate in business-to-business transactions (B2B), implementing Law 18/2022 on the creation and growth of companies.

What does this Royal Decree regulate?

The Royal Decree establishes the technical and operational requirements of the electronic invoicing system, including:

• The conditions under which electronic invoices must be issued, transmitted and received between businesses and professionals.
• The requirements to be met by electronic invoice exchange platforms.
• The creation and operation of a public electronic invoicing solution managed by the Spanish Tax Agency (AEAT).
• Reporting obligations concerning invoice statuses, particularly acceptance and payment.

How will the system work?

The Spanish electronic invoicing system will consist of:

• Private electronic invoice exchange platforms, and
• A public electronic invoicing solution.

Companies will be able to use:

• private platforms,
• the public solution,
• or a combination of both.

In certain cases, private platforms will be required to send an exact copy of the invoice to the public solution.

Electronic invoice formats

Invoices must be issued in a structured format compliant with the European EN16931 model, using one of the following syntaxes:

• UBL
• CII
• EDIFACT
• Facturae

Information on invoice status and payment

The Royal Decree introduces new reporting obligations:

Invoice recipients will be required to report, among other matters:

• the commercial acceptance or rejection of the invoice,
• and full payment, including the payment date.

This information must be reported within a maximum of 4 calendar days (excluding Saturdays, Sundays and national public holidays).

Payment must also be reported to the public electronic invoicing solution, even when private platforms are used.

Purpose of the regulation

According to the text, the measure is intended to:

• improve traceability throughout the invoicing cycle,
• obtain reliable information on payment periods,
• reduce late payment in commercial transactions,
• and promote the digitalisation of companies, particularly SMEs.

Entry into force and implementation

The Royal Decree:

• enters into force 20 days after its publication,
• but its effective implementation is subject to a ministerial order that will establish the public electronic invoicing solution.

Once that order is approved, the obligations will apply in two stages:

• 12 months for companies with turnover exceeding 8 million euros.
• 24 months for all other businesses and professionals.

Current situation

At present, the mandatory business-to-business electronic invoicing system is not yet enforceable in practice, pending the corresponding ministerial order and regulatory development.

If your company needs to adapt to this new system, it is advisable to begin reviewing your invoicing processes and the technology solutions available.