Spain has taken a decisive step toward implementing mandatory business-to-business (B2B) e-invoicing with the publication of Royal Decree 238/2026 on 31 March 2026, following its approval by the Council of Ministers. This long-anticipated regulation develops Law 18/2022 (the “Create and Grow” Law) and establishes the technical and operational framework for the future mandatory use of e-invoices between entrepreneurs and professionals in Spain (for prior coverage, see the article in the January 2025 issue of Indirect Tax News).
The Royal Decree marks another milestone in the digitalisation of tax-related processes and aligns with the broader EU trend towards enhanced digital reporting, greater transactional transparency and strengthened oversight over commercial activity.
Law 18/2022 introduces the obligation for entrepreneurs and professionals to issue, send and receive e-invoices for all B2B transactions, with phased implementation based on turnover. This measure forms part of a wider policy agenda aimed at accelerating business digitalisation and addressing late payment practices in commercial relationships.
Although the legislative e-invoicing obligation is already in place, its practical application required secondary legislation defining the technical, functional and operational rules of the e-invoicing system (for prior coverage, see the article in the January 2022 issue of Indirect Tax News). The newly approved Royal Decree provides that missing framework and enables the system’s implementation.
The regulation sets out the core elements of the Spanish B2B e-invoicing model and confirms that implementation will follow a phased approach. Key aspects include:
Mandatory B2B e-invoicing represents more than a formal invoicing change—it signals a structural shift in how transactional data is generated, exchanged and monitored. Businesses should not wait for the technical specifications to begin preparing. The transition will require system upgrades, process redesign and enhanced coordination across functions. Key preparation areas include:
Alvaro Gomez-Elvira
BDO in Spain
The Royal Decree marks another milestone in the digitalisation of tax-related processes and aligns with the broader EU trend towards enhanced digital reporting, greater transactional transparency and strengthened oversight over commercial activity.
Background
Law 18/2022 introduces the obligation for entrepreneurs and professionals to issue, send and receive e-invoices for all B2B transactions, with phased implementation based on turnover. This measure forms part of a wider policy agenda aimed at accelerating business digitalisation and addressing late payment practices in commercial relationships.Although the legislative e-invoicing obligation is already in place, its practical application required secondary legislation defining the technical, functional and operational rules of the e-invoicing system (for prior coverage, see the article in the January 2022 issue of Indirect Tax News). The newly approved Royal Decree provides that missing framework and enables the system’s implementation.
Key Features and Implementation Timeline
The regulation sets out the core elements of the Spanish B2B e-invoicing model and confirms that implementation will follow a phased approach. Key aspects include:
- Mandatory B2B e-invoicing: Entrepreneurs and professionals will be required to issue, transmit and receive e-invoices in their transactions with other businesses.
- Invoice status reporting: Taxpayers will need to report information on the status of invoices (e.g., issued, accepted, rejected or paid), increasing transparency and traceability across the invoicing lifecycle.
- Interoperability model: The system will combine private e-invoicing platforms with a public solution provided by the Spanish tax authorities, ensuring full interoperability.
- Focus on late payment control: The reporting of invoice status, particularly payment information, is intended to improve visibility and strengthen oversight of payment behaviour.
- One year later for taxpayers with annual turnover exceeding EUR 8 million; and
- Two years later for all other taxpayers.
BDO Perspective
Mandatory B2B e-invoicing represents more than a formal invoicing change—it signals a structural shift in how transactional data is generated, exchanged and monitored. Businesses should not wait for the technical specifications to begin preparing. The transition will require system upgrades, process redesign and enhanced coordination across functions. Key preparation areas include:
- Ensuring ERP and invoicing systems can support the future e-invoicing model;
- Implementing processes to track and report invoice status throughout the lifecycle; and
- Strengthening collaboration between tax, finance and IT to ensure consistency and data integrity.
Alvaro Gomez-Elvira
BDO in Spain