Ley Crea y Crece – Spain’s interoperable B2B e-invoicing model

Ley Crea y Crece introduces mandatory B2B e-invoicing in Spain through an interoperable model that combines private exchange platforms and the public e-invoicing solution managed by the AEAT. Royal Decree 238/2026 develops this framework, and Ministerial Order HAC/1028/2026, published in the Official State Gazette on 5 October 2026, regulates the public e-invoicing solution and started the countdown for the phased rollout. The model also introduces invoice-status communication requirements designed to improve payment transparency, monitor payment practices and support interoperability between private platforms and the public system.

Understanding Spain’s B2B eInvoicing model under Ley Crea y Crece

Key implementation dates

Key milestones in the phased rollout of Spain’s B2B eInvoicing framework

Deadlines are counted from 6 October 2026, when Ministerial Order HAC/1028/2026, which regulates the public e-invoicing solution, entered into force under Royal Decree 238/2026. Beyond the rollout dates, businesses should also prepare for the operational impact of invoice-status communication, interoperability requirements and integration with the public e-invoicing solution.

06/10/2027

Companies with a VAT turnover above €8 million in the previous year must issue and receive structured e-invoices and report invoice and payment statuses. For the first 12 months, each e-invoice must be accompanied by a legible PDF, unless the recipient expressly accepts the original format. Private exchange platforms must also meet their interoperability obligations from this date.

06/10/2028

All other businesses and professionals must issue and receive e-invoices. Legal entities with a turnover of up to €8 million must also report invoice and payment statuses.

06/10/2029

Self-employed individuals and income-attribution entities must report invoice and payment statuses. Until then, reporting is voluntary for them.

How Spain’s Ley Crea y Crece eInvoicing model works

Implementation

Phased from 6 October 2027 (turnover above €8 million) and 6 October 2028 (all other businesses and professionals)

Tax Authority

Agencia Estatal de Administración Tributaria (AEAT) – Spanish Tax Agency

Format

EN 16931 semantic model. Between private platforms: UBL, CII (UN/CEFACT), EDIFACT or Facturae, with conversion between them. The public solution and faithful copies use UBL

Digital Signature

Advanced electronic signature of the issuer (or authorized delegated signature) for invoices issued through private platforms

Archiving

Electronic invoices must be stored for at least 4 years in line with Spanish tax record-keeping requirements

Other Spanish regulations

VeriFactu, SII, FACe, TicketBAI

Invoice Status Communication

Recipients must report commercial acceptance or rejection and full payment within four calendar days (excluding weekends and national holidays). Full payment or rejection and the payment due date must also be reported to the public solution

See how Code10 helps SAP-based businesses prepare for Ley Crea y Crece compliance in Spain

Frequently asked questions

Who is required to use e-Invoicing under the "Ley Crea y Crece"?

The obligation applies when the invoice recipient is a business or professional established or resident in Spain. It is phased in from 6 October 2027 for companies with a turnover above €8 million and from 6 October 2028 for all other businesses and professionals, with status reporting for self-employed individuals from 6 October 2029. Exceptions include simplified invoices (except qualified simplified invoices), the electricity and regulated gas market operators, IATA transactions settled through CASS, BSP or SIS-ICH, and other operations temporarily excluded by ministerial order.

What formats are allowed for electronic invoices?

Invoices must follow the EN 16931 semantic model. Between private platforms, UBL, CII (UN/CEFACT), EDIFACT and Facturae are accepted, and platforms must be able to convert between them while preserving authenticity and integrity. Ministerial Order HAC/1028/2026 establishes UBL as the syntax of the public e-invoicing solution and of the faithful copies sent to it, which cannot include embedded files. Invoice statuses are reported to the AEAT through web services or a web form.

Is an electronic signature mandatory for e-invoicing?

Yes, for invoices issued through private platforms: they must carry the issuer’s advanced electronic signature, or an authorized delegated signature. Invoices issued through the public e-invoicing solution follow the authentication procedures established by the AEAT.

Who reports invoice statuses under the Spanish model?

The recipient must inform the issuer of commercial acceptance or rejection and of full payment, with their dates, within four calendar days (excluding weekends and national holidays). Full payment or rejection, together with the payment due date, must also be reported to the public solution; if no rejection is reported, the invoice is presumed accepted. Issuers may voluntarily report collection, non-payment or date differences. The payment obligation is considered fulfilled when the invoice already includes a payment date equal to or earlier than its issue date.

How does the public solution interact with private platforms?

Businesses may work through private platforms, the public solution, or both. When the public solution is not used directly to issue invoices, a faithful electronic copy of each invoice must be submitted simultaneously to the public solution in UBL format. The public solution is free of charge, and recipients can retrieve their invoices from it at any time. Private platforms must accept any interconnection request free of charge and have it working within one month; until then, invoices are deposited in the public solution. The public solution must be available at least two months before the first effective application.

Does the law apply to B2G transactions as well?

No, the “Ley Crea y Crece” focuses on B2B transactions. However, B2G einvoicing has been mandatory in Spain since 2015 through the FacturaE system.

Different Frameworks for SAP Integration And Ley Crea Y Crece Compliance

Ley Crea y Crece marks an important milestone in the digitalization of Spain’s B2B invoicing model. It requires the electronic exchange of structured invoices between businesses, private platforms and the public e-invoicing solution, together with mandatory invoice-status communication.

As a result, SAP and ERP systems must be able to generate compliant invoice data, validate structured formats such as UBL, submit faithful copies when required, exchange messages with public or private platforms, and reconcile invoice statuses within finance and compliance processes.

At Code10, we support this transition through SAP standard capabilities via the Document and Reporting Compliance framework, combined with advanced eCompliance integration delivered through our eCompliance Hub. This allows companies to prepare for Spain’s B2B e-invoicing mandate with a scalable architecture for invoice generation, validation, transmission, status tracking and long-term regulatory maintenance.

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