Mandatory B2B e-invoicing: deadlines and costs for businesses and self-employed 2026

Key data

All businesses and self-employed professionals operating in the Spanish B2B market face a new obligation they cannot ignore: issuing and receiving invoices in electronic format. Real Decreto 238/2026, published on 31 March 2026 and entering into force on 25 March 2026, implements the mandate of the Ley Crea y Crece and makes electronic invoicing a legal requirement for all transactions between businesses and professionals in Spain.

This regulation is not a recommendation or an option: it is a legal obligation with differentiated deadlines based on company size and with expressly provided penalties for those who fail to comply.

What does this regulation establish?

Real Decreto 238/2026 regulates four major areas that directly affect the operations of any business or self-employed professional invoicing another company:

• Accepted technical formats: The regulation defines which electronic formats are valid for issuing invoices in B2B transactions. Invoicing systems must generate documents in these formats to be legally valid.
• Requirements for invoicing software systems: Management software, ERP systems and invoicing software must meet specific technical standards established in the decree. Not every current software system will automatically be compliant.
• Obligations for data retention and submission to the Agencia Tributaria: Businesses must not only issue electronic invoices, but also retain them correctly and submit data to the Agencia Tributaria in accordance with the procedures established by the regulation.
• Amendment of the 2012 Invoicing Regulation: The decree updates Real Decreto 1619/2012, of 30 November, which previously governed invoicing obligations, to adapt it to the new digital framework.

Economic and operational impact

The impact of this regulation is not merely administrative: it has direct consequences on the operational costs and management systems of any business.

Companies that already have an ERP or invoicing software must verify whether their provider has updated the solution to comply with the new technical standards. In many cases, this will involve costs for updating, migrating or replacing software.

Companies with turnover exceeding 8 million euros have less time to adapt, making this review an immediate priority for that segment. SMEs and self-employed professionals have an additional transitional period, but it is not indefinite.

Non-compliance may result in significant penalties, as the regulation expressly warns. Although the decree does not detail specific fine amounts in the available summary, the explicit reference to material penalties indicates that the economic risk of failing to adapt is real and significant.

Additionally, the obligation to submit data to the Agencia Tributaria represents a change in internal accounting and administration processes, which will need to be adapted to ensure ongoing compliance.

Who is affected?

This regulation affects any business or professional that issues or receives invoices in business-to-business (B2B) transactions in Spain. Specifically:

• Companies with turnover exceeding 8 million euros: obligation with shorter deadlines.
• SMEs with B2B transactions: obligation with an additional transitional period.
• Self-employed professionals invoicing other businesses or professionals: included in the scope with a transitional period.
• Those responsible for ERP systems, invoicing software and financial management: must verify the compatibility of their tools.
• CFOs, finance directors and tax advisors: must plan the adaptation and review data submission processes to the Agencia Tributaria.

B2C transactions (business to end consumer) are not included within the scope of this regulation.

Practical example

A consulting services company with annual turnover of 12 million euros that currently issues invoices as PDFs by email and records them in an ERP system from several years ago finds itself in the following situation:

• By exceeding 8 million euros in turnover, it falls into the group with shorter deadlines for adaptation.
• It must verify whether its current ERP meets the technical requirements of Real Decreto 238/2026. If it does not, it will need to update or replace its software before its deadline expires.
• It will need to configure data submission processes to the Agencia Tributaria in accordance with the new standards.
• If it fails to act in time, it faces the significant penalties provided for in the regulation.

An SME with €500,000 in annual turnover has more leeway thanks to the additional transitional period, but must equally begin reviewing its systems to avoid missing its deadline when it arrives.

What should businesses do now?

1. Identify which group you belong to: Determine whether your turnover exceeds 8 million euros to know whether the shorter deadlines or the transitional period for SMEs and self-employed professionals applies to you.
2. Audit your invoicing software or ERP: Contact your software provider to confirm whether the current solution meets the technical requirements of Real Decreto 238/2026 or whether it requires an update.
3. Review invoice retention processes: Ensure that your digital archiving system complies with the retention obligations established in the regulation.
4. Prepare data submission to the Agencia Tributaria: Configure or adapt internal processes to ensure data is sent to the Agencia Tributaria in accordance with the new standards.
5. Inform your tax advisor: Share this regulation with your advisory firm so that the adaptation is included in the 2026 tax compliance plan.
6. Establish an adaptation timeline: Define internal dates for review, testing and go-live of the new system before your legal deadline expires.

Official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-7295