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Practical VAT Guide 2026.

Electronic invoice required

It has been published in the BOE Royal Decree 238/2026, of March 25, which develops the mandatory electronic invoicing system between businesses and professionals and which modifies the Regulation governing invoicing obligations, approved by Royal Decree 1619/2012, of November 30.

This Royal Decree defines the basic features of the Spanish electronic invoicing system, made up of private electronic invoice exchange platforms and the public electronic invoicing solution.

Specifically, this Royal Decree establishes the technical and information requirements of the Spanish system of mandatory electronic invoicing between businesses and professionals and the requirements applicable to private platforms for the exchange of electronic invoices.

The State Tax Administration Agency will develop a free application or formwhich, under certain conditions and requirements, will allow all entrepreneurs and professionals and, where appropriate, their authorized representatives, to issue electronic invoices, generate information on the status of electronic invoices, including their full effective payment, and make this information available to counterparties and the Public Administration using the public electronic invoicing solution.

The effective application The implementation of this Royal Decree will be conditional upon the entry into force of the order that will regulate the public electronic invoicing solution and will be as follows:

  • Twelve months after the entry into force of the order for entrepreneurs and professionals whose volume of operations has exceeded 8 million euros during the immediately preceding calendar year.

  • Twenty-four months after the order comes into force, for the rest of the business owners and professionals.

The Ministerial order regulating the public electronic invoicing solution currently under reviewIt will include the technical elements necessary for the correct functioning of the public electronic invoicing solution, the forms of authentication, identification and representation to access said public solution, the specifications of the payment communication service to it, the terms of use of the syntax UBL in this regard; the unique encoding of electronic invoices and their insertion into the invoice syntax, the communication between the public electronic invoicing solution and private invoicing platforms; as well as any other technical requirements that may be necessary for the proper implementation and maintenance of the public electronic invoicing solution.