Compulsory electronic invoicing: what is known today

Exactly what it requires

Ley 18/2022, the so-called «Crea y Crece», established that all business people and professionals must issue, send and receive electronic invoices in their commercial dealings with other business people and professionals. And it added something that gets less comment and will mean more work: issuer and recipient will have to report the invoice's statuses.

Watch the scope, because a lot of people get confused here: it is an obligation between businesses and professionals. Invoices to private individuals are outside it.

The stated aim is not anti-fraud but against late payment: if it is on record when each invoice is accepted and when it is paid, real average payment periods can be measured.

The regulation is now published

For three years the law was waiting for its implementing regulation. That regulation arrived with Real Decreto 238/2026, of 25 March, which has been in force since 20 April 2026.

What it lays down, in brief:

• A mixed system. Private exchange platforms coexist with a public platform run by the Tax Agency, which is free and also works as a universal repository.
• Four accepted formats, all built on the European semantic model: CII, UBL, EDIFACT and Facturae. Private platforms have to be able to convert between all of them.
• A copy to the public platform. Anyone who does not use it to issue still has to send it a faithful copy of every invoice.
• Compulsory statuses: commercial acceptance or rejection and its date, and full actual payment and its date. Within four calendar days, excluding Saturdays, Sundays and national holidays.
• Left out are simplified invoices — except those carrying the customer's NIF, address and VAT — the regulated electricity and gas markets and the airline sector's clearing houses.

When it will be compulsory: the honest answer

The deadlines, once the clock starts, are these:

There is a draft of that order which went to public consultation in April 2026 and pointed to coming into force on 1 October 2026. But a draft is not a rule: until it is published, any specific date you read — including the «compulsory in 2027» claims going around — is a forecast, not an obligation.

We would rather say «there is no date yet» than give one that has to be corrected later. It has already happened twice with VeriFactu.

Why it is not the same as VeriFactu

It is the most widespread confusion in the market, and it comes from both sounding like «that thing about invoices and the tax office». They separate like this:

And one thing that ties them together, even though neither refers to the other — RD 238/2026 does not mention the VeriFactu regulation even once: VeriFactu applies to any system used to issue invoices, whether they are electronic or not. In other words, complying with one does not exempt you from the other, and the system that issues electronic invoices will have to be a compliant system as well.

And the one that has existed for years: invoicing the public sector

Almost every article forgets it, but there is an electronic invoicing obligation in force since January 2015: invoicing the public sector.

It applies to public and private limited companies, to other legal persons and to certain entities, which have to submit their invoices to the public sector in Facturae format through the corresponding general entry point — FACe in the case of central government.

Administrations may exclude invoices of up to €5,000 by regulation, but it is a power each one has, not an automatic exemption. It is worth checking with the body you invoice before taking it for granted.

What Cairos does with this, and what it does not

It generates the Facturae 3.2.2 XML for any invoice, with the VAT breakdown, the IRPF in its withholdings block, the recargo de equivalencia inside the tax it belongs to and the collection account. And before generating anything it checks what the registry is going to reject: above all the body's three DIR3 codes — accounting office, managing body and processing unit — which cannot be worked out because the body itself supplies them. If one is missing, it says so on screen instead of handing you a file that will be rejected three days later.

And what it does not do, which matters just as much: it does not sign the file. It lacks the XAdES electronic signature, which is exactly what FACe requires. The XML is useful for reviewing, for sending to your gestoría or for uploading to a portal that signs on its own account, but uploading it to the registry as it is comes back rejected. There is no automatic sending either: the file is downloaded, it is not submitted from Cairos.

What is worth doing now

Little, and calmly. The obligation is not enforceable yet, and rushing to buy a platform «to comply» is exactly what to avoid while there is no rule.

• Having your customers' NIFs and tax details right. It sounds obvious, but a structured invoice does not forgive a misspelt NIF or an incomplete address.
• Keeping track of when each invoice is paid. That information is going to be compulsory, and today many people do not have it written down anywhere.
• Issuing with software, not with a template. The leap from Word to a system is the real work; once it is made, the format is the least of it.
• Not buying anything out of fear until there is a date.

In Cairos we already keep the payment date of every invoice and the full tax details of every contact, because they are needed for other things. When the obligation arrives, the preparatory work will be done.