Electronic invoicing between businesses will be mandatory.

On March 31, Royal Decree 238/2026 was published in the Official State Gazette (BOE), establishing the framework for the new mandatory electronic invoicing system for businesses and professionals. With this new regulation, sending invoices on paper or in PDF format without legal validity will no longer be an option in commercial transactions.

The measure applies to all companies and professionals who issue or receive invoices from other businesses or professionals operating in Spain, that is, to the vast majority of the business sector.

Transactions with end consumers and simplified invoices (tickets) are excluded from this obligation.

With the implementation of this system, several relevant changes occur:

• Invoices must be issued and received in a structured electronic format, beyond the conventional PDF.
• The recipient must confirm whether they accept or reject the invoice and inform the payment date.
• Both the invoice and the information associated with the payment will be recorded in a system managed by the Tax Agency (AEAT).
• Companies with a turnover exceeding 8 million euros will have a 12-month transition period in which they must also attach a legible PDF along with the electronic invoice.

The decree has been in force since April 20, 2026, but the effective obligation of electronic invoicing will depend on the publication of a Ministerial Order from the Ministry of Finance, which is still pending.

The adaptation periods will be as follows:

• Companies with a turnover exceeding 8 million euros: 12 months from the publication of the Ministerial Order.
• Other companies and professionals: 24 months from the publication of the Ministerial Order.

Companies will be able to adapt through two main avenues, which can be combined:

• Through the AEAT’s free public platform, accessible to any company or professional.
• Through private electronic invoice exchange platforms, which must be approved and connected to each other and to the public solution.

Given this new scenario, it is recommended to:

• Check if the current billing software is compatible with the new system or needs updating.
• Analyze the billing volume to determine the adaptation period.
• Pay attention to the publication of the Ministerial Order of Finance, which will mark the start of the calculation of the deadlines.

Adapting to mandatory electronic invoicing can raise questions from both a technical and tax perspective. At CINC Asesoría, we help you review your processes, adapt your invoicing system, and comply with regulations without complications.

If you want to prepare your company for this change or need personalized advice, contact us and we will accompany you throughout the entire process.