Mandatory e-invoicing in Spain: deadlines for autónomos

Mandatory e-invoicing between businesses and the self-employed in Spain starts on 6 October 2027 if your business volume in the previous year was over €8 million, and on 6 October 2028 for everyone else, including autónomos (self-employed workers) below that threshold. In 2026 it cannot yet be enforced as a general rule.

This guide covers the timetable, how to tell which date applies to you, which formats are valid, how payment statuses work and a full worked example with numbers. If you are looking for somewhere to issue your invoices, our invoicing page is linked at the end too.

What an electronic invoice is (and what it is not)

Under these rules, an electronic invoice is a structured file that software can read with no human input: each piece of data (tax ID or NIF, taxable base, VAT rate, total) sits in a specific field. Being digital is not enough.

Royal Decree 238/2026 requires every invoice to follow the European semantic model EN 16931 and use one of these four syntaxes (art. 7):

• UBL (Universal Business Language), the syntax used by the public solution of Hacienda, the Spanish tax authority.
• CII (Cross Industry Invoice), defined by UN/CEFACT.
• EDIFACT, also from UN/CEFACT.
• Facturae, the Spanish format you will already know if you have invoiced public bodies.

That rules out three things many people call an "electronic invoice": a PDF sent by email, a photo or scan of a paper invoice, and an Excel or Word file exported to PDF. They are digital, but not structured.

The minimum content of an invoice does not change: it is what we explain in how to invoice as self-employed in Spain. What changes is the format and the channel you send it through.

When does e-invoicing become mandatory? The official timetable

The timetable is already in the BOE, Spain's official gazette. Royal Decree 238/2026 (fourth final provision) counts the deadlines from the date the ministerial order on the public invoicing solution comes into force. That order is Order HAC/1028/2026 of 2 October: it was published in the BOE on 5 October 2026 and, under its sole final provision, came into force the next day, 6 October 2026.

The AEAT, Spain's tax agency, confirmed the timetable in a news item on 7 October 2026:

(opens the image in a new tab)

The timetable comes from the law itself. The eighth final provision of Law 18/2022, known as the Crea y Crece Law, gave one year for anyone invoicing over €8 million and two years for everyone else, counted from the implementing regulations. Royal Decree 238/2026 turns that into 12 and 24 months from the order.

How to tell which date applies to you

The €8 million is business volume (volumen de operaciones) in the immediately preceding calendar year (for the 2027 date your 2026 volume counts; for the 2028 date, your 2027 volume), worked out under article 121 of the VAT Law. The fourth final provision of RD 238/2026 points to that article itself. In practice it is the amount of your supplies of goods and services in a year excluding VAT, with a few exclusions (occasional sales of property or capital goods, for example).

The Crea y Crece Law and B2B e-invoicing

"B2B" means transactions between businesses (business to business). Article 2 bis of Law 56/2007 has existed since 2013 (it was added by Law 25/2013 of 27 December), but Law 18/2022, known as the Crea y Crece Law, amended it so that it now opens like this: every business and professional must issue, send and receive electronic invoices in their commercial dealings with other businesses and professionals.

That creates three obligations, not one:

1. Issue and send your invoices in electronic format.
2. Receive your suppliers' invoices in electronic format.
3. Exchange information on the status of each invoice: whether it is accepted, whether it is rejected and when it is paid.

The third is the real novelty. The law's stated goal is not just digitalisation but tackling late payment: with this information it will be possible to see how long companies take to pay their invoices.

E-invoicing for the self-employed: who it covers and who it does not

The scope is set out in article 3 of Royal Decree 238/2026: transactions between businesses or professionals where the customer has its registered office, a permanent establishment or its home in Spain, provided the transaction is for that establishment in Spain.

It affects you if you invoice companies or other autónomos established in Spain (a designer working for agencies, a plumber repairing the office of a gestoría (tax and accounting agency)), and also if you receive invoices from suppliers that are companies or autónomos: your coworking space, your adviser, your materials supplier.

(opens the image in a new tab)

Sales that are excluded

The following invoices you issue fall outside the obligation:

• Sales to consumers. Invoices to private individuals are not included.
• Simplified invoices, formerly known as tickets. Article 4 excludes them, except the qualified ones under article 7.2 of the Invoicing Regulation: those requested by a business or professional that show their NIF, their address and the VAT amount separately. We explain this in simplified invoices: limits and when to use them.
• Customers outside Spain. If the customer is not established in Spain, the Spanish obligation does not apply to that invoice.

Even if all your sales are excluded, you are not out of the system. If you receive invoices from suppliers that are companies or autónomos in Spain, you may still have to receive them in electronic format and report their payments (art. 2 bis of Law 56/2007). There are also some very specific exclusions (the electricity market, the gas market, airline tickets settled through IATA platforms) in the second additional provision of the royal decree, which almost never affect an autónomo.

What if I already invoice public bodies?

Invoicing a public administration is governed by a different law, Law 25/2013. Its article 4 makes electronic invoices compulsory mainly for companies and other entities; individuals are not on that list, although they can use it. Invoices go through each administration's general entry point (FACe for the central government and many others; some regions have their own). That law stays the same. What is new is the obligation with your private customers.

How an electronic invoice is sent: platforms and the public solution

You will have two ways to issue and send your invoices:

1. A private platform or invoicing program that issues in one of the four formats and connects with the others. Platforms must be interconnected with each other free of charge for the exchange, and your customer cannot force you to use a specific provider (art. 2 bis of Law 56/2007).
2. The public e-invoicing solution (SPFE) run by the AEAT. Under Order HAC/1028/2026, using it to issue invoices is free and voluntary, it is designed for SMEs and professionals, it issues in UBL format (art. 3) and you can access it with a digital certificate or, for some functions, with Cl@ve.

(opens the image in a new tab)

The SPFE also receives a true copy of the invoices that go through private platforms. In other words, Hacienda will have access to the electronic invoices covered by this obligation whichever channel you use. Private platforms must send that copy twelve months after the order came into force, from 6 October 2027 (fourth final provision, section 2, of RD 238/2026).

The order requires the SPFE to be available at least two months before the first mandatory date (second additional provision), so you should be able to try it by 6 August 2027 at the latest. The technical specifications and usage limits (invoice volume) are those published on the AEAT website.

What if your customer has no platform or program?

You do not have to sort out their side. If your customer has not agreed with you to receive invoices through a private platform and has not published its own invoice entry point, the rules treat it as receiving through Hacienda's public solution, without it having to do anything (art. 6, sections 1 and 3, of RD 238/2026). You issue through your platform or the SPFE and the invoice reaches them that way; private platforms can use the SPFE as an interconnection point (art. 8.2). What your customer then does with the invoice is their obligation, with its own date.

Invoice statuses: acceptance, rejection and payment

This is the part that changes day-to-day work the most. Whoever receives an invoice must report:

• Whether they accept or reject it commercially, and on what date (art. 10.1.a of Royal Decree 238/2026). If they reject it, they give the reason (the content is in Annex II of Order HAC/1028/2026). In the SPFE there is no need to report acceptance: if there is no rejection and no later corrective invoice, the invoice is presumed accepted (art. 7 of Order HAC/1028/2026).
• The date of full actual payment, under articles 10 and 12.
• The due date of the payment, under article 12.3.

Whoever issues the invoice can also report, voluntarily, that they have been paid or that they have not (art. 12.4).

The self-employed get some breathing room: the third transitional provision of RD 238/2026 postpones the obligation to report status and payments for individuals and pass-through entities whose business volume was not over €8 million in the previous calendar year. They start on 6 October 2029. Until then, reporting is voluntary.

Worked example: Lucía, a self-employed designer, in November 2028

Lucía is a self-employed graphic designer in Valencia. She invoices about €48,000 a year, mostly to agencies, and is taxed under the direct assessment method (estimación directa). Let's follow one of her invoices after 6 October 2028.

Step 1. She issues the invoice. On Friday 3 November 2028 she invoices a project to an agency (a limited company with €2 million of business volume):

The maths: 1,200 × 0.21 = 252; 1,200 × 0.15 = 180; 1,200 + 252 − 180 = 1,272. 21% is the standard VAT rate (article 90 of Law 37/1992) and 15% is the general withholding for professional activities under personal income tax, IRPF (article 95.1 of the IRPF Regulation). If you want to check when 7% applies instead, we explain it in IRPF for autónomos.

(opens the image in a new tab)

Step 2. She sends it in electronic format. A PDF by email no longer works. Lucía generates it in UBL or Facturae if she uses a private platform, or in UBL if she uses the public solution, and sends it to the customer through that channel.

Step 3. The agency reports the statuses. The agency is a company at €8 million or less, so from 6 October 2028 it must report invoice status and payment. It accepts the invoice on Monday 6 November and pays the €1,272 on Thursday 16 November. Even though both use private platforms, the agency reports the statuses to Lucía (art. 10) and also the payment to the SPFE (art. 12.1); it can authorise its platform to do this (art. 12.2). The deadline is the same for both and, unless a special rule says otherwise, the payment day itself does not count: the count starts the next day (art. 5.1 of the Civil Code). So: Friday 17 (day 1), Saturday 18 and Sunday 19 (not counted), Monday 20 (day 2), Tuesday 21 (day 3) and Wednesday 22 (day 4). That is 4 days for these purposes spread over 6 calendar days (17 to 22). The agency must report the payment by Wednesday 22 November 2028 at the latest. This holds as long as the 2028 working calendar does not put a national holiday on those dates; a holiday that is only regional or local does not extend the deadline.

Step 4. Lucía receives invoices from her suppliers. Her coworking space invoices her €150 plus €31.50 of VAT every month (€181.50 in total). From 6 October 2028 that invoice reaches her in electronic format and Lucía must be able to receive it. As an individual below €8 million, she does not yet have to report that she has paid it: that obligation reaches her on 6 October 2029.

What changes in the amounts: nothing. The base, the VAT and the withholding are the same as with a PDF. What changes is the format, the channel and the fact that, from 6 October 2029, she will have to report her own payments to suppliers.

E-invoicing and VeriFactu: not the same thing

They are two different obligations that are often confused. VeriFactu is one of the two options under the Regulation on the requirements for invoicing software systems, approved by Royal Decree 1007/2023: either the program sends each record to Hacienda straight away, or it stores them in a way that ensures they cannot be altered.

VeriFactu's exclusions include, for example, anyone on the SII and anyone whose tax domicile is in the Basque Country or Navarre and who is subject to those regions' own (foral) tax rules (arts. 1.3, foral territories, and 3.3, SII, of the Regulation approved by RD 1007/2023). The SII (Immediate Supply of Information) is the system some companies already use to send their VAT books to Hacienda.

On VeriFactu's dates, you need to separate what has been approved from what has been announced:

• Approved: Royal Decree-law 15/2025 set 1 January 2027 for companies that pay Corporate Income Tax and 1 July 2027 for everyone else, autónomos included. These are the dates in the AEAT's note.
• Announced, pending legislation: on 5 October 2026, the Ministry of Finance published a note titled "Previsión de modificación de los plazos de aplicación de las obligaciones pendientes" (planned change to the deadlines for pending obligations), announcing that those obligations would be postponed "until October 2028, to make them coincide with mandatory e-invoicing" for anyone not over €8 million.

You will find the details in what VeriFactu is and VeriFactu: when it comes into force.

What happens if you do not comply

Law 56/2007 provides for a warning or a fine of up to €10,000 for businesses that are required to comply, once the obligation applies to them, and do not offer the option of receiving electronic invoices or do not let former customers access their invoices (art. 2 bis, section 9).

Beyond the fine, the practical risk is different: once the obligation reaches you, your customer can reject an invoice that does not arrive in a valid format, and that can hold up the processing of your payment.

Until your date (6 October 2028 if you are an autónomo and not over €8 million), this obligation does not apply to you yet. The other invoicing rules, such as the Invoicing Regulation or, where relevant, Law 25/2013 with public bodies, remain in force.

Common mistakes

• Thinking it is already mandatory in 2026. The general obligation between businesses cannot yet be enforced in 2026, although some specific earlier obligations exist (FACeB2B in certain public contracts, for example). Plenty of software advertising suggests otherwise.
• Believing a signed PDF is enough. When the obligation reaches you, you will need a structured format (UBL, CII, EDIFACT or Facturae).
• Mixing up e-invoicing and VeriFactu. They are different rules, with different dates and different aims.
• Forgetting the receiving side. You will not only issue electronic invoices, you will also have to receive them from your suppliers.
• Ignoring payment statuses. You will have to report when you pay your suppliers, within the period in the box above:
  • If you are an individual or a pass-through entity and not over €8 million of business volume, from 6 October 2029 (third transitional provision of RD 238/2026).
  • If you are above that figure, from 6 October 2027.
• Switching software without checking its roadmap. If you are choosing a tool in 2027, ask whether it will issue in a structured format and whether it will comply with VeriFactu.

Checklist to get ready from today

1. Check your business volume for the calendar year immediately before each date (box 108 of Form 390) to know which timetable applies to you.
2. List your customers: how many are companies or autónomos in Spain and how many are consumers.
3. Check whether your invoicing software plans to issue in UBL or Facturae and connect with other platforms.
4. Ask your regular suppliers how they will send you their invoices.
5. Note the dates that apply to you from point 1: 6 October 2027 if you are over €8 million; if not, 6 October 2028 (issuing and receiving) and 6 October 2029 (status and payments). Add 1 July 2027, the legal VeriFactu date today, with a postponement to October 2028 announced.

How Melso helps

Melso is your AI tax agent, with human professionals behind it. With Melso invoicing, Melso prepares your invoices, you check the details and approve the exact version in the app, and only then are they issued; a "yes" in the chat does not issue any invoice. Day to day on WhatsApp, Melso sorts your income and expenses, spots what is missing and lets you look up your upcoming taxes. Which services your plan includes depends on your activity and tax profile: see the plans and confirm the scope with Melso before you sign up.

Get started at melso.ai or message us on WhatsApp if you have questions about your case.

This article is for information only and does not replace professional advice for your case. Last reviewed: 12 October 2026.