Electronic invoice: what it is, what it's for, and when to implement it

Between 2027 and 2028, the way companies invoice each other will completely change in Spain. The Crea y Crece Law and its regulation (RD 238/2026) require freelancers and companies to issue their B2B invoices in electronic format, and the dates are already set.

If you invoice other professionals, it's wise to understand what the change entails before the deadline catches up with you. Throughout the article, you'll see what counts as an electronic invoice, when it applies to you based on your billing, and what you need to be ready.

What is an electronic invoice?

An electronic invoice is an invoice issued and received in a structured electronic format, with the same legal and fiscal validity as a paper invoice. It is a document generated by computer means that certifies a delivery of goods or a provision of services and should not be confused with the Verifactu system.

The word that changes everything is structured. It's not enough for the file to be digital: it must be encoded in a format that the recipient's system can read and process without human intervention.

Structured and unstructured electronic invoice

Within what we colloquially call a digital invoice, there are two different realities, and only one of them complies with the regulation:

• Unstructured: a PDF, a Word document, or a scan. Processing it requires human intervention or text recognition software. It is not considered an electronic invoice for the purpose of the obligation.
• Structured: it is generated and transmitted in a standardized data format (Facturae, UBL, CII, or EDIFACT). The recipient's system reads, validates, and accounts for it automatically. This is what the law requires.

The use of structured electronic invoices is already mandatory for transactions with the Administration, and its use will progressively extend to all sectors and economic actors from 2027, as stipulated by the Crea y Crece Law.

Electronic invoice, digital invoice, and paper invoice

These three terms are often used as synonyms, but they are not. The table summarizes how they differ and why only one of them will be valid when the obligation comes into effect:

The practical consequence is simple: continuing to send PDFs to another company will no longer be valid once the mandatory calendar applies to you.

Features of the electronic invoice: technical requirements and data it must include

The requirements are at two levels: the conditions that any invoice must guarantee, whether paper or electronic, and the technical requirements that only apply to electronic invoices.

The three conditions every invoice must guarantee

1. Readability: the content must be readable and interpretable clearly.
2. Authenticity of origin: the identity of the issuer and the person obliged to issue the invoice must be accredited, which can be the same person.
3. Integrity of content: it must be ensured that the data has not been modified since its issuance.

These three conditions must be maintained from issuance to the end of the conservation period. In the electronic invoice, they are met through the structured format and the advanced electronic signature, although the regulation also admits other equivalent means, such as electronic data interchange (EDI) or any system agreed upon by the parties that offers the same guarantees. For invoices directed to the public administration in Facturae format, the electronic signature is mandatory.

Technical requirements of the electronic invoice

An unstructured digital file, like the PDF resulting from scanning a paper invoice, does not comply with the regulation. For an invoice to be considered electronic, it must:

• Be issued in a structured format according to the European standard EN 16931: Facturae, UBL, CII, or EDIFACT.
• Be generated with software that complies with the regulation, or with the public billing solution of the Tax Agency when available.
• Ensure interoperability, so that it can be read and managed by the different systems and platforms used by the issuer and recipient.
• Ensure the recipient's access to the file, with the possibility to read, copy, download, and print it.
• Be preserved in digital format for at least four years, maintaining its integrity, accessibility, and traceability.

What data must it include

The mandatory fields are the same as in a traditional paper invoice:

• Identification data and tax address of the issuer and recipient.
• NIF or CIF of both parties.
• Invoice number and series, unique and sequential.
• Date of issuance and, if different, date of the transaction.
• Description of the goods delivered or services provided.
• Taxable base, applied VAT rate, and resulting amount.
• IRPF withholding when applicable, and total amount.

Is the QR code mandatory on the electronic invoice?

The QR code, the alphanumeric identifier, and the mention "Invoice verifiable at the AEAT electronic headquarters" do not come from the electronic invoice regulation but from the regulation of billing systems. They are requirements of Verifactu, a different obligation with its own schedule.

In practice, you may have to comply with both at the same time: issuing in structured format for the electronic invoice and adding the QR and mention for Verifactu. Check with your software which of the two applies to you now and which is yet to come, as each requires different things.

Who is required to issue electronic invoices?

The obligation is activated by the type of transaction, not by the size of your business. If you issue an invoice to another company or freelancer (a B2B transaction), it affects you. The only thing that changes based on your billing is the date you start.

These dates depend on a ministerial order that has not yet been published, expected for October 2026, so these are the forecasts set by RD 238/2026:

Relations between companies and professionals (B2B)

• Large companies: annual billing exceeding 8 million euros. Mandatory likely from October 1, 2027.
• SMBs and freelancers: billing equal to or less than 8 million euros. Mandatory likely from October 1, 2028.

Relations with the public sector (B2G)

• Prior obligation: companies, freelancers, and joint ventures that deliver goods or provide services to a public body have been required since 2015, under Law 25/2013, and must submit the invoice at the corresponding general entry point, such as FACe.
• 5,000 euro threshold: Article 4 of the same law allows each administration to exclude invoices up to 5,000 euros from the obligation. Many have done so by regulation, but not all, so it's advisable to check with the body you invoice before assuming it.

Territories with their own regional regulations

Some communities have developed their own system, which does not replace the state calendar but coexists with it:

• Basque Country: TicketBAI, already in force in Álava, Bizkaia, and Gipuzkoa.
• Navarre: own model in development (Na-ticket), under conditions similar to those of the Crea y Crece Law.
• La Rioja and Galicia: specific features in the electronic invoice of La Rioja and the electronic invoice of the Xunta.

Who is exempt from electronic invoicing?

The exemption depends on the type of transaction, not the sector or billing volume. These are the three cases that are excluded:

• Transactions with end consumers (B2C). If you sell to an individual, you can continue to provide them with a PDF or a paper ticket. Note a nuance: the registration of that sale may be subject to Verifactu, which is another distinct obligation.
• Simplified invoices (tickets). The regulation expressly excludes them, whether the recipient is an individual or a professional.
• Recipients without residence, headquarters, or establishment in Spain. This includes many intra-community and export transactions, which are governed by their own control mechanisms.

There is no general exemption by sector of activity or for billing below a certain threshold: if your volume is low, you are not exempt from the obligation, you simply enter the second phase. The pending ministerial order may specify additional cases, so it's advisable to review it when published.

When will electronic invoicing be mandatory?

Royal Decree 238/2026, approved by the Council of Ministers on March 24, 2026, and published in the BOE on March 31, develops the regulation of electronic invoicing between companies and professionals.

It came into force on April 20, 2026, but the clock for the obligation does not start with it: it starts with the ministerial order regulating the public billing solution, expected on October 1, 2026.

From that date, two periods open, one and two years:

How does electronic invoicing work?

The process has five phases, and the fourth is new compared to the traditional invoice: the recipient must return the document's status to you.

1. Creation. You draft the invoice with the fiscal data of the transaction using an invoicing program adapted or through the public solution. The system checks that the file meets legal requirements and generates it in the structured syntax your client accepts.
2. Signature. The document is sealed with an electronic certificate that certifies the issuer's identity and allows detection of any subsequent alteration of the content, or with another equivalent means admitted by the regulation.
3. Sending and receiving. The invoice is transmitted electronically. If the recipient is a public administration, the sending is done through FACe; if it is another company or freelancer, through the exchange platform you use, with a copy to the public billing solution of the Tax Agency. The recipient's system validates and processes it automatically, and it can even trigger payment and archiving.
4. Status communication. The recipient is obliged to inform whether the invoice has been accepted, rejected, or paid, and on what date. This record allows you to track your collections without calling anyone.
5. Storage. You keep the file in digital format for at least four years, intact, accessible, and traceable in case of an inspection requirement.

For example, if you issue an invoice on the 3rd, your client accepts it on the 5th, and pays it on the 28th, those three dates are recorded. This traceability is what will allow measuring the actual payment terms between companies.

If you work with the Administration, the reference format is Facturae. Before considering the invoice valid, it's advisable to validate the electronic invoice to rule out format errors that could cause rejection.

Advantages of electronic invoicing

Beyond compliance, the format change has measurable effects on the daily management of a business:

• Speed. Sending and receiving are immediate, and the recipient's system processes the invoice automatically, shortening validation and payment cycles.
• Savings. Costs of paper, printing, sending, and physical archiving disappear, and the time spent manually entering data is reduced.
• Security. The structured format and signature reduce the risk of manipulation, document loss, and errors when transferring information to accounting.
• Control of delinquency. As the acceptance and payment date of each invoice is recorded, the actual terms are no longer an estimate.

That last point explains much of the regulation: reducing delinquency between companies is the declared goal of the Crea y Crece Law. Its effect will depend on the real adoption among SMBs and freelancers and on the interoperability of different invoicing systems.

What regulations govern electronic invoicing?

Four regulations cover the ground, and it's important not to confuse them as each imposes different obligations:

• Law 18/2022, Crea y Crece: introduces the obligation of electronic invoicing in transactions between companies and professionals, aiming to reduce delinquency and increase transparency in payment terms.
• Royal Decree 238/2026: develops this obligation. It sets the format, the copy to the public solution, the communication of statuses, and the implementation calendar.
• Law 25/2013: has required electronic invoicing to public administrations through general entry points since 2015.
• Royal Decree 1619/2012: approves the Billing Obligations Regulation, which remains the basis for what data an invoice must contain and how it should be preserved.

Additionally, the Law 11/2021, known as the Anti-Fraud Law, does not regulate electronic invoicing but the computer systems with which it is issued. From it, Verifactu arises, and in the Basque Country, its equivalent is TicketBAI.

Penalties for non-compliance with electronic invoicing

The sanctioning regime is divided between the Crea y Crece Law, which specifically penalizes not offering electronic invoicing, and the General Tax Law, which sanctions non-compliance with billing obligations with percentages on the amount of the affected transactions.

Apart from these, using software that does not comply with the anti-fraud regulation has its own set of infractions, which you can consult in the details of the Verifactu penalties and fines.

Frequently asked questions

Can I continue sending invoices in PDF?

To individual clients, yes. In transactions between companies and professionals, you will no longer be able to do so when your deadline applies, in October 2027 or October 2028, depending on your billing volume.

Can Excel still be used for invoicing?

No. The regulation requires that the invoicing system guarantees the integrity, traceability, and immutability of the records, and an editable spreadsheet cannot offer those guarantees. It's important to clarify a point that causes confusion: the Tax Agency does not grant an approval seal to programs, it is the manufacturer who certifies through a responsible declaration that their software complies with the regulation. We develop this in the article on Excel and Verifactu.

What invoicing software do I need?

One that can generate the structured format, communicate with the public solution, and, if applicable, also comply with Verifactu. The Administration has FACe as a general entry point for invoices and MiFacturae, a web application for generating invoices directed to the public sector, but neither covers invoicing between companies. For that, you will need your own or third-party program.

What format do I have to use?

Any of the syntaxes admitted according to the European standard EN 16931: Facturae, UBL, CII, or EDIFACT. Facturae is the reference format in Spain and the one used with public administrations.

What if my client is abroad?

If the recipient does not have residence, headquarters, or establishment in Spain, the transaction is outside the scope of the Spanish regulation, and you are not obliged to issue an electronic invoice in the format it requires.

Do I need a digital certificate?

You need a mechanism that guarantees the authenticity and integrity of the document. In practice, the invoicing software handles the electronic signature, although a valid certificate will be required to operate with public platforms.

Prepare your electronic invoicing with Holded

The exact date when the obligation affects you depends on your billing volume, but preparation should not be left to the last minute: it involves changing format, reviewing your clients' fiscal data, and adapting how you send and archive each document.

With Holded, you can issue and receive invoices in the formats required by the regulation, maintain the traceability of each sending, and keep them accessible throughout the legal period, without changing your way of working. The software updates as regulatory developments are published, so you don't have to chase every regulatory change.

Start with the basics: check which phase of the deadline you are in and confirm that your invoicing program can generate the structured format when your date arrives. With that resolved, the rest of the change is a matter of configuration.