What actually binds a Spanish business, and from when
Three separate rules, three separate timetables, and plenty of people selling you the wrong urgency. This is what is published in the Spanish official gazette today, kept apart from what has only been announced.
Business-to-business e-invoicing
Invoices between businesses and professionals have to travel as structured electronic documents, and their payment status has to be reported.
Dates
- In force6 October 2026The tax agency's public platform is regulated: the clock starts· Orden HAC/1028/2026
- In force6 October 2027Businesses turning over more than €8M the previous year· RD 238/2026, disp. final 4.ª a)
- In force6 October 2028Every other business and professional, self-employed included· RD 238/2026, disp. final 4.ª b)
What usually goes unsaid
A PDF by email is not an electronic invoice. What counts is a file the other side's software reads by itself; the PDF only rides along, and only for the first twelve months.
Sources
- RD 238/2026, de 25 de marzo (texto consolidado) (BOE-A-2026-7295)
- Orden HAC/1028/2026, de 2 de octubre (BOE-A-2026-20587)
- Ley 18/2022, de 28 de septiembre («Crea y Crece») (BOE-A-2022-15818)
VeriFactu
The software you invoice with has to sign every invoice and chain its hash, so an issued invoice cannot be deleted or altered.
Dates
- In force29 July 2025Invoicing software vendors· RD 1007/2023
- In force1 January 2027Companies paying Spanish corporate income tax· RD-ley 15/2025
- In force1 July 2027Self-employed and all other taxpayers· RD-ley 15/2025
- Announced, unpublishedOctober 2028Businesses invoicing under €8M· anuncio del Ministerio de Hacienda de 5 de octubre de 2026
What usually goes unsaid
It does not force you to change software: it forces the software to comply. If yours adapts, there is nothing to buy.
Sources
- RD 1007/2023, de 5 de diciembre (texto consolidado) (BOE-A-2023-24840)
- RD-ley 15/2025, de 2 de diciembre (BOE-A-2025-24446)
Working-time records
Recording when each employee starts and finishes every day, and keeping it for four years.
Dates
- In force12 May 2019Every employer, on paper or digitally· RD-ley 8/2019, art. 34.9 ET
- In process, not bindingNo dateMandatory digital records, accessible remotely· proyecto de real decreto, sin publicar
What usually goes unsaid
Recording is mandatory; using an app is not. Paper is still legal. Anyone telling you otherwise is selling you something.
Sources
- Estatuto de los Trabajadores, art. 34.9 (texto consolidado) (BOE-A-2015-11430)
- RD-ley 8/2019, de 8 de marzo (BOE-A-2019-3481)
Consolidated texts read in the Spanish official gazette on 3 November 2026. If another site shows a different date, check it against the gazette link before believing it, whoever it comes from.
What people ask us
Is business-to-business e-invoicing already mandatory in Spain?
Not yet, but the clock is running. Royal Decree 238/2026 left the deadlines hanging on a ministerial order, and that order — Orden HAC/1028/2026 — came into force on 6 October 2026. From that date, businesses whose turnover exceeded €8 million the previous year have twelve months, so 6 October 2027, and everyone else, self-employed included, has twenty-four months: 6 October 2028.
Does a PDF sent by email count as an electronic invoice?
No. A mandatory electronic invoice is a structured file that the recipient's software reads by itself, with nobody typing anything. A PDF is a picture of an invoice for a person to read. For the first twelve months, businesses over €8 million must send a legible PDF alongside the electronic invoice, but the PDF accompanies it: it does not replace it.
Are VeriFactu and e-invoicing the same thing?
No, and mixing them up is the costlier of the two mistakes. VeriFactu is about how an invoice is issued: the software has to sign it and chain its hash so it cannot be deleted or altered afterwards. E-invoicing is about how it travels: it has to reach the customer in a format their software understands on its own. Two separate rules, two separate timetables, and both have to be met.
Do we have to change our invoicing software?
Not necessarily. VeriFactu requires the software to comply, not that it be new. Most vendors are adapting theirs, because the rule has bound them since 29 July 2025. What is worth doing is asking your provider two things in writing: whether the version you pay for will comply, and whether the upgrade is covered by your maintenance contract or billed separately.
Is a time-clock app mandatory in Spain?
No. Recording each employee's hours has been mandatory since 12 May 2019, but the law does not say how: paper remains valid as long as the record is daily, reliable and kept for four years. A draft royal decree would require records to be digital and remotely accessible, but as of 1 November 2026 it has not been published in the official gazette, so it does not bind.
Why do so many sources say digital time tracking is already mandatory?
Because most pages explaining Spanish time-recording rules are written by someone selling a time-clock app. The draft royal decree has been in process since 2025, and several approval dates announced during 2026 came and went. Until the text appears in the official gazette, what binds is article 34.9 of the Workers' Statute, which does not require a digital medium.
What happens if we do not comply?
Spain's General Tax Act has its own penalty regime for invoicing software, in article 201 bis, covering both holding or using non-compliant systems and producing or selling them. For working-time records, a missing register is an offence in employment law and the Labour Inspectorate enforces it. The amounts depend on the case and are worth confirming with your accountant.
We are a small business in Mallorca. Where do we start?
By asking whoever already sells you the software, before buying anything. If you invoice with a program, write to the vendor and ask in writing whether it meets VeriFactu and what the plan is for e-invoicing. If you invoice with Excel or Word templates, that is where something does have to be built before 2027. And if what you still do by hand is job reports and hours, no rule forces that: change it when it pays off, not out of fear.
Want to know which of these applies to you, and which does not?
Tell us what you invoice with and how you track hours. We will tell you what has to move before 2027, what can wait and what needs no change at all. If an update from your current provider is enough, we will say so.
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