B2B e-invoicing: the timetable is now in motion

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Mandatory e-invoicing between businesses and professionals now has dates. On 5 October 2026, the BOE (Spain’s Official State Gazette) published Order HAC/1028/2026, which regulates the Tax Agency’s public e-invoicing solution. The order came into force on 6 October 2026, starting the countdown set by Royal Decree 238/2026, the regulation implementing Law 18/2022, known as the Crea y Crece Act. Businesses and professionals with turnover above 8 million euros in the previous year will have to issue and receive electronic invoices from 6 October 2027. Everyone else must do so from 6 October 2028.

How we got here

In 2022, the Crea y Crece Act established the obligation to issue, send and receive electronic invoices in transactions between businesses and professionals, but it left the details to a regulation. That regulation is Royal Decree 238/2026 of 25 March, published in the BOE on 31 March 2026. It sets out the technical and information requirements for the system, as well as those for private invoice exchange platforms. It also amends the Invoicing Regulation (Royal Decree 1619/2012).

The royal decree did not set a specific date: the deadlines were counted from the entry into force of a ministerial order on the public solution. That is the order that has just been published, so we can now put a date on each obligation.

Implementation timetable

According to the notice published by the Tax Agency on 7 October 2026, the timetable is as follows:

  • 6 October 2027: businesses and professionals with a volume of operations above 8 million euros. They must issue, send and receive electronic invoices and report the status of invoices and payments.
  • 6 October 2028: all other businesses and professionals, for issuing, sending and receiving electronic invoices. From that date, legal entities with 8 million euros or less must also report the status of invoices and payments.
  • 6 October 2029: individuals and entities under the income attribution regime, who until then may report the status of their invoices on a voluntary basis.

During the 12 months following 6 October 2027, large companies must accompany the electronic invoice with a readable PDF, unless the recipient expressly accepts the electronic original. The obligation applies to transactions where the recipient is a business or professional established in Spain. Simplified invoices are generally excluded.

What the AEAT public solution is

The order describes the public solution as a basic, free platform, designed primarily for SMEs and professionals. It must be available at least two months before the first effective application date, that is, before 6 August 2027. Its main features are:

  • Format: invoices follow the European semantic model EN 16931 in UBL syntax.
  • Copy to the Tax Agency: anyone invoicing through a private platform must send a faithful copy in UBL to the public solution at the time of issue.
  • Unique code: each invoice is identified by the issuer’s tax ID (NIF), the series, the number and the issue date. Duplicates are rejected.
  • Private platforms: those exchanging invoices through the public solution must automatically retrieve their customers’ invoices and make them available to them immediately.
  • Access: with an electronic certificate, or with Cl@ve if the form is used. Third parties acting on behalf of a company must be registered in the AEAT’s register of powers of representation.

Payment status, the big novelty

Electronic invoicing is not only about issuing invoices. The recipient will have to report whether they reject the invoice and the date on which it was paid in full. They have four calendar days from the actual payment, not counting weekends or national public holidays. If there is no rejection or corrective invoice, the invoice is deemed accepted. The issuer, for its part, may voluntarily report receipt of payment, non-payment or discrepancies in dates.

With this information, the public solution will make the status of each invoice available to the parties and to the tax authorities. This makes actual payment times visible, one of the aims of the Crea y Crece Act in the fight against late payment.

What this means for your company

Twelve months may seem like a lot, but changing how a company invoices and collects payments takes time. In addition, this obligation is different from Verifactu: Verifactu sets the requirements for invoicing software, whereas B2B e-invoicing regulates how the invoice is exchanged with the customer. We recommend that you:

  • Check your 2026 volume of operations to find out whether the 2027 or the 2028 deadline applies to you.
  • Decide whether you will use the public solution, a private platform or a connection from your own ERP.
  • Review the quality of your customer and supplier data (tax IDs, addresses, payment terms), because the UBL format leaves no room for improvisation.
  • Prepare your administration team to record payment dates and respond to rejections within four days.

How we see it at Binovo

At Binovo we work daily with invoicing in Odoo 16 and with helping companies adapt to Verifactu through Verifactu in Odoo. Our recommendation is to start with your data and processes before thinking about the tool. Once the AEAT publishes the final technical specifications, integrations with the public solution or with private platforms can be addressed with a custom development. If you would like to review how the timetable affects your company, you can contact us.

Binovo is developing two solutions for this obligation. If you use Odoo, an e-invoicing module that will be public on our GitHub: we explain it in E-invoicing in Odoo. If you use other software, the B2B e-invoicing API (in Spanish), built on the same technology as the Verifactu API. On that page we also compare Verifactu and B2B e-invoicing, because they are two different obligations.

Sources

Transparency: this article was prepared with the help of artificial intelligence based on the sources cited and was reviewed and validated by the Binovo team before publication.

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