2025: E-invoicing is now law for start-ups, but the timetable is still pending
The mandatory use of electronic invoicing in transactions between businesses and professionals (B2B) has been approved by Law 18/2022 on Business Creation and Growth. The effective entry into force for the private sector depends on the publication of the Royal Decree that technically develops the obligation. As of 2025, this regulation is still being processed, so the exact implementation schedule is pending its publication in the Official State Gazette (BOE).
Dates and regulatory status (2025)
- B2B obligation (Law 18/2022): signed into law, awaiting regulation.
- Provisions of the draft Regulation: phased implementation according to turnover:
- Companies with a turnover > €8 million: 1 year from the entry into force of the Regulation.
- Other companies (start-ups, SMEs and self-employed workers): 2 years from the entry into force of the Regulation.
- B2G: e-invoicing already mandatory in public procurement.
Relationship with VERI*FACTU (invoicing software requirement)
Regardless of the B2B calendar, the Regulation on computerised invoicing systems (Royal Decree 1007/2023, amended by RD 254/2025) sets firm dates for adapting invoicing software:
- Companies (corporate tax payers): before 1 January 2026.
- Other taxpayers (e.g. self-employed persons not subject to corporation tax): before 1 July 2026.
These deadlines affect technical preparation (integrity, traceability, QR/code, sending/verification of records) and coexist with the future B2B obligation under Law 18/2022.
Who is required to comply
- All companies and professionals operating in Spain in B2B relationships (including start-ups and SMEs).
- B2C (business-to-consumer) transactions in the private sector are excluded, without prejudice to the customer receiving an electronic invoice if so agreed.
- In the B2G sphere, electronic invoicing is already mandatory for contracting with the public sector.
How startups and SMEs must comply (action plan)
- Diagnosis: inventory billing systems and collection/payment circuits, and verify compatibility with the requirements of RD 1007/2023 (and its amendment by RD 254/2025).
- Compliant software: select or update an ERP/invoicing programme that complies with the integrity, preservation, legibility, traceability and inalterability of records; and that can issue invoices in a structured format.
- Structured formats: prepare the issuance/receipt in formats compatible with the European standard EN 16931 (e.g., UBL, CII, EDIFACT or Facturae), as established by the final regulation.
- Interoperability and interconnection: ensure the exchange of invoices with public/private platforms and accessibility by authorised third parties (customers, suppliers, government).
- Invoice statuses: configure status communication (acceptance/rejection/payment) within the deadlines set by the regulation; the drafts contemplate short deadlines (e.g., 4 business days).
- Digital storage: establish electronic archiving policies with guarantees of integrity and access.
- Governance and compliance: update internal policies, controls and training for the finance and operations team.
Standard technical requirements for B2B e-invoicing
- Structured and validatable data (PDF alone is not sufficient).
- Electronic signature/stamp and time stamp as appropriate.
- Verification code/QR code in accordance with applicable regulations.
- Traceable record of invoice dispatch, receipt and status.
- Free and non-discriminatory interconnection between platforms.
Risks of non-compliance
- Administrative and tax penalties.
- Loss of subsidies or exclusion from public procurement.
- Operational incidents (invoice rejections, payment delays) and reputational damage.
Legal framework
- Law 18/2022, of 28 September (Create and Grow Law).
- Law 58/2003, General Tax Law.
- Royal Decree 1619/2012, Invoicing Regulations.
- Royal Decree 1007/2023 and Royal Decree 254/2025 (computerised invoicing systems – VERI*FACTU).
- Directive 2014/55/EU (B2G) and European standard EN 16931 (e-invoice semantics).
Conclusion
The B2B electronic invoicing obligation has been approved by law, and its effective implementation depends on pending regulations. To avoid falling behind, start-ups must begin adapting to VERI*FACTU (deadline 2026) and developing the capacity to issue and receive structured, interoperable, and traceable invoices. Those who get ahead of the curve will reduce risks, speed up collections, and gain operational efficiency.
| RDecreto 254 2025 Facturacion electronica | 218 KB |
