Spain: Council of Ministers approves e-invoicing mandate for B2B transactions

Spain’s Council of Ministers on March 24, 2026, approved a royal decree introducing a mandatory electronic invoicing (e-invoicing) system for business-to-business (B2B) transactions. The measure aims to accelerate the digitalization of the Spanish business environment, reduce late payments, and improve cash flow predictability, especially for small and medium-sized enterprises (SMEs). The implementation will be phased, with a one-year deadline for companies with annual revenue exceeding €8 million and a two-year deadline for all other businesses, starting from the publication of the ministerial order regulating the public e-invoicing platform.

Background

According to the Minister of Economy, Spain has one of the highest average payment periods in the EU, at around 80 days, which exceeds both the 60-day maximum established by the Late Payment Law and the EU average. This situation restricts the growth and competitiveness of Spanish businesses. The B2B e-invoicing mandate is designed to address this challenge by providing full traceability of the invoicing cycle. By electronically recording when each invoice is issued, accepted, and paid, companies will have greater control over their cash flows, and the tax authority will be able to monitor compliance with payment deadlines.

The e-invoicing mandate develops Article 12 of Law 18/2022 (Ley Crea y Crece) and aligns with the European Commission’s VAT in the Digital Age (VIDA) initiative.

Scope of the decree

Spain will use a five-corner e-invoicing model in which a structured, machine-readable file will be required instead of PDF, Excel, and paper formats. Taxpayers must report the status of each invoice, including acceptance and the actual payment date. This complete traceability is a key tool to combat late payments.

Taxpayers can exchange e-invoices via two channels:

1. Private platforms, which must be interconnected so that no company is forced to use its client’s platform
2. A free public platform developed by the Spanish tax authority (Agencia Estatal de Administración Tributaria, AEAT), accessible to all businesses and professionals, including those with low invoice volumes

The system will allow companies to save time and resources by automating processes and enabling accounting software to directly process large volumes of structured invoices.

The implementation will be phased:

• Companies with annual revenue above €8 million must comply within one year.
• All other companies must comply within two years.

The timeline starts from the publication of the technical ministerial order, expected before July 1, 2026.

Differences with Verifactu

The B2B e-invoicing mandate is distinct from the Verifactu project, which targets fiscal fraud and imposes obligations on invoicing software providers. Verifactu has already entered into force, but its effects are deferred until 2027.

Next steps

Pending details include the technical specifications for the public platform, which will be defined in the upcoming ministerial order. Transitional relief is provided, with phased deadlines based on company size. Stakeholders need to monitor the publication of the ministerial order for registration and testing requirements.

For more information, contact a KPMG tax professional:

Miguel Ferrández Amorós | mferrandez@kpmg.es
Natalia Pastor Caballero | npastor@kpmg.es
Philippe Stephanny | philippestephanny@kpmg.com
Lyubov Skenderova | skenderova.lyubov@kpmg.com
Manuel Montero Izard | manuelmontero1@kpmg.com
Ramon Frias | ramonfrias@kpmg.com