Law 18/2022 “Crea y Crece” · RD 238/2026 · Order HAC/1028/2026
From October 2027 for large businesses and October 2028 for all others, invoices between businesses and sole traders must be data, not PDFs. Here’s what the rules say, with sources, and how to comply without changing how you invoice.
Updated 15 October 2026 with the BOE and Tax Agency.
Law 18/2022, “Crea y Crece” (Create and Grow), requires invoices between businesses and professionals to be electronic. Its rules have been approved: Royal Decree 238/2026, dated 25 March (published in the BOE on 31 March 2026).
It has a different aim from Verifactu: tackling late payment, not fraud. So, as well as specifying the format, it requires you to know whether each invoice is accepted and when it is paid.
An e-invoice isn’t a PDF sent by email, even if it’s signed. It’s a structured data file your customer’s software can read without anyone typing anything:
It applies to businesses and sole traders invoicing other businesses or professionals established in Spain. The deadlines started on 6 October 2026, when Order HAC/1028/2026, governing the AEAT public service, came into force:
Royal Decree 238/2026 allows four syntaxes, all based on European standard EN 16931:
You can use any of the four with your customer. PDFs, photos and Excel files don’t qualify.
Two separate, complementary requirements. Regifactu covers both in one module.
Covers: how your software records each invoice. Rules: Law 11/2021 and RD 1007/2023. Reports to: the AEAT. Requires: a linked hash, QR code and record submission. Invoice format: any (your usual PDF is fine). Aim: prevent fraud. Scope: all invoices, including receipts and sales to consumers.
Covers: how invoices reach your customer. Rules: Law 18/2022 and RD 238/2026. Reports to: your customer and the AEAT. Requires: structured format, copy to the public service, status and payment. Formats: UBL, CII, EDIFACT or Facturae. Aim: tackle late payment. Scope: business-to-business invoices only.
For you, almost nothing. The software does the work; you still click Validate.
When you validate, the software creates a UBL invoice signed with your certificate, as well as the Verifactu record. The QR-code PDF is still there for anyone who wants to read it; the data file is the official invoice.
A faithful UBL copy goes to the Tax Agency’s public service as soon as the invoice is issued. Queuing, retries and pending items all appear on the same screen you already use for Verifactu.
The recipient must say whether they accept or reject the invoice and give the date of full payment within four calendar days (excluding Saturdays, Sundays and national holidays). Regifactu handles this automatically: “accepted” when you validate a received invoice, “paid” when you reconcile the payment in Bitfin. No new forms to fill in.
E-invoices you receive are added without typing: supplier, line items and due date. Bitia already does this with emailed PDFs; structured data makes it even more reliable.
No duplicate setup. Your certificate, live/test switch, resending and accountant export are the same ones you already use for VERI*FACTU.
The linked hash, QR code, document types and responsible declaration all stay as they are. E-invoicing works alongside them; it doesn’t replace them.
As usual. One button handles both the Verifactu record and the e-invoice.
The invoice is generated in UBL under EN 16931 and signed with your certificate, with line items, taxes and due dates.
A copy goes to the AEAT public service as soon as it’s issued. If anything fails, it stays pending and is retried automatically.
Invoices received in UBL or Facturae become supplier invoices without typing: supplier, line items and due date.
Accepted, rejected or paid, shown on the invoice and matched against the payment in Bitfin.
Everything in your ERP, with no extra software or platform to learn.
Linked SHA-256 hash, QR code on every invoice and submission to the AEAT using your certificate. Ready to use.
Invoices are issued in signed UBL, with a faithful copy sent to the AEAT public service.
Supplier invoices are converted automatically, with no typing.
Acceptance, rejection and payment for each invoice, with a reminder of the four-day deadline.
If you also invoice in Ecuador, authorise e-invoices with the SRI from the same ERP.
Yes, when invoicing other businesses or sole traders. From 6 October 2028, they must issue, send and receive invoices electronically; from 6 October 2029, they must report status and payment (Order HAC/1028/2026).
Invoices between businesses and professionals must be issued, sent and received in structured electronic format, with their status and payment reported (Law 18/2022, Article 12). Royal Decree 238/2026 sets out the rules, and Order HAC/1028/2026 sets the deadlines: 6 October 2027 for businesses with turnover above €8 million and 6 October 2028 for all others.
From 6 October 2027 if your turnover exceeds €8 million, and from 6 October 2028 in all other cases. The deadlines run from 6 October 2026, when Order HAC/1028/2026 came into force.
Not for this requirement. The invoice must be a structured data file compliant with EN 16931 (UBL, CII, EDIFACT or Facturae). A PDF doesn’t qualify, even if signed.
No. The requirement applies only between businesses and professionals. Simplified invoices are excluded, except for qualified simplified invoices. Verifactu, however, also applies to receipts and sales to consumers.
It’s the Tax Agency platform that receives a copy of every invoice and stores its status. It’s free and lets businesses without their own software issue invoices too. You can use it or a private platform.
Four calendar days from payment, excluding Saturdays, Sundays and national holidays. The recipient has the same time to report whether they accept or reject the invoice (Royal Decree 238/2026, Articles 10 and 12).
No. Verifactu governs how your software records each invoice for the AEAT; e-invoicing governs how it reaches your customer and how payment is reported. Regifactu covers both in one module, with the same certificate.
Facturae is Spain’s e-invoice format, already used for invoicing public authorities. UBL is the international standard used by the Peppol network and required by the AEAT for copies received by its public service.
The module is part of Regifactu and works with the rest of the system:
Already invoicing with Regifactu? Activation takes a 30-minute chat. If not, we’ll tell you exactly what you need today to comply with VERI*FACTU and what you’ll need for e-invoicing.
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