Key takeaways
- Spain published the final draft of the “Ley Crea y Crece Ordinance” in March 2025, setting the stage for mandatory B2B e-invoicing.
- All e-invoices must use UBL syntax and can be transmitted via a public or private e-invoicing platform.
- Large companies must comply one year after final publication; SMEs get two years.
- Linked legislation, the Veri*factu Ordinance, delays software compliance until 2026.
- The initiative promotes transparency, fraud prevention, and digital transformation in business transactions.
Spain has moved closer towards modernizing its invoicing system with the long-awaited implementation of mandatory B2B electronic invoicing. A final draft of the “Ley Crea y Crece Ordinance” has now been published on the Ministry of Economy, Commerce and Enterprise’s website, opening a public consultation period until April 7, 2025.
This legislative move is part of a broader push to increase business transparency, reduce fraud, and streamline tax compliance. Here’s a breakdown of what the final draft entails and what it means for businesses operating in Spain.
What’s in the final draft?
Compared to the version submitted to the European Commission back in January 2024, this latest draft introduces some notable updates, particularly around technical standards and implementation timelines:
- Mandatory UBL syntax: All e-invoices transmitted via the public e-invoicing solution must use UBL (Universal Business Language) syntax. This requirement also applies to invoice copies submitted to the public platform when a private e-invoicing system is used.
- Staggered implementation timeline:
- Large companies (with annual turnover exceeding €8 million) will be required to comply one year after the Ministerial Order is published in the Official Gazette.
- All other companies will have two years from that date to comply.
- This means mandatory e-invoicing is unlikely to begin before the second half of 2026.
- Large companies (with annual turnover exceeding €8 million) will be required to comply one year after the Ministerial Order is published in the Official Gazette.
Who will be affected?
The Ordinance will apply only to B2B local transactions, meaning:
- E-invoicing will not be mandatory when the customer is a business not established in Spain or lacking a permanent business site in the country.
- Non-resident companies will only be subject to e-invoicing obligations if their local B2B transactions are carried out through a permanent establishment in Spain for indirect tax purposes.
Invoicing software requirements
Alongside e-invoicing, the Spanish government is also introducing the use of approved invoicing software in accordance with Royal Decree 1007/2023, widely known as the “Veri*factu Ordinance.”
Initially, companies under this rule were expected to comply by July 1, 2025. However, delays in publishing the accompanying technical specifications (Ministerial Order HAC/1177/2024) have led to a proposed amendment. As a result, the Veri*factu software compliance deadline is also expected to shift to 2026.
What’s next?
Following the close of the public consultation period on April 7, 2025, the Ordinance must still be approved by Spain’s Council of Ministers and formally published in the Official State Gazette. After that, a separate Ministerial Order will outline the specifics of the public e-invoicing solution.
This staggered but definitive rollout gives companies time to adapt—but preparation should begin now. Ensuring invoicing systems are both UBL-compatible and compliant with Veri*factu standards will be key to avoiding disruptions when the new rules take effect.
Frequently asked questions
What is the Ley Crea y Crece Ordinance?
A Spanish law introducing mandatory B2B e-invoicing to enhance transparency and digital efficiency.
When will e-invoicing become mandatory?
Likely between late 2026 and 2027, depending on company size.
Who must comply first?
Large businesses with turnover over €8 million must comply one year after publication; smaller companies two years later.
What format must invoices use?
All e-invoices must follow the UBL (Universal Business Language) standard.
Does the rule apply to foreign companies?
Only if they have a permanent establishment in Spain conducting B2B transactions.
What is the Veri*factu Ordinance?
A related regulation requiring certified invoicing software; implementation now expected in 2026.
What’s the goal of the reform?
To reduce fraud, improve compliance, and align Spain with EU digital tax standards.
