E-invoicing (electronic invoicing) is becoming mandatory in Spain. Under the Crea y Crece Law, companies and freelancers will gradually have to switch to electronic invoices when they bill other businesses and professionals; sales to private customers are not covered by this mandate. This guide explains what changes for freelancers and small firms, when it will apply to you, which free tools can help with compliance and which mistakes to avoid.
What is e-invoicing in Spain?
An e-invoice is an invoice in a structured, machine-readable format, such as Facturae or UBL, that the client's system can record without anyone retyping the data. In Spain, the Crea y Crece Law, approved in 2022, will make e-invoicing mandatory for all entrepreneurs and professionals (empresarios y profesionales), that is, businesses and self-employed professionals, in their dealings with one another.
What Crea y Crece requires
It sets three requirements:
- a machine-readable electronic format;
- delivery through a digital channel;
- reporting the status of each e-invoice, such as accepted or paid.
The aim is to improve transparency, reduce fraud and fight late payment.
Who has to comply
- Covered: businesses and professionals of any size, including freelancers, in their dealings with one another; only the start date changes. If you are still setting up, see our guide to becoming an autónomo as a foreigner.
- Not covered: invoices to private customers, although a separate rule for billing systems can still apply to them.
Why PDFs don't count
A PDF sent by email is not an e-invoice under Crea y Crece, even with a digital signature. It works like a photo of the document: a person can read it, but a computer cannot reliably extract its content.
Timeline: when will e-invoicing be mandatory?
The implementation dates are now set. The deadlines in Royal Decree 238/2026 count from 6 October 2026, when Order HAC/1028/2026, the ministerial order that regulates the public e-invoicing solution, took effect. According to the AEAT implementation calendar, B2B e-invoicing becomes mandatory in two phases, always on 6 October:
- 2027: large businesses and professionals, whose volume of operations exceeded 8 million euros in the previous year;
- 2028: all other businesses and professionals, freelancers included.
Reporting the status of invoices and payments comes later for freelancers: from 6 October 2029 for individuals and for entities under the income attribution regime (régimen de atribución de rentas), such as a comunidad de bienes; until then, it is voluntary. Large businesses report from 2027 and companies from 2028. Some business clients may still ask you to switch sooner.
Verifactu vs e-invoicing: two separate compliance obligations
Verifactu sets requirements for the invoicing software you work with, whoever your client is; the e-invoicing mandate sets how invoices between businesses must be produced and exchanged. You may have to comply with both.
| Aspect | Crea y Crece (e-invoicing) | Verifactu |
|---|---|---|
| What it regulates | Invoices between businesses, sent digitally | The billing programs you use, for any client |
| Format | Machine-readable, as explained below | Does not set one |
| Compliance check | That your tool produces machine-readable files | Its manufacturer's declaración responsable |
What Verifactu asks of your software
It comes from a royal decree on invoicing systems. A compliant system:
- creates an unalterable billing record for each invoice, chained to the previous one, and adds a QR code to the document;
- either sends the records to the AEAT or keeps them under stricter security requirements;
- comes with a declaración responsable in which the manufacturer self-certifies compliance.
It does not apply to taxpayers who keep their VAT records through the SII, or to those taxed under the Basque or Navarre regional systems, which have their own rules (TicketBAI in the Basque Country). It also has its own calendar: according to a Tax Agency notice, companies that file Corporate Income Tax must adapt their systems before 1 January 2027, and everyone else, freelancers included, before 1 July 2027.
The SII: real-time VAT reporting
Spain's SII (Suministro Inmediato de Información) is a separate VAT reporting system that works in near real-time: billing records go to the AEAT within four days, weekends and national holidays excluded. The SII is mainly mandatory for large companies and a few other groups; other taxpayers can join voluntarily. If in doubt, ask your gestor.
What does a valid e-invoice need?
A valid e-invoice must use an accepted format, include the usual details, ensure its authenticity and integrity, and be kept for the required period.
How machine-readable formats work
A structured format stores each piece of data (issuer, tax ID, description, taxable base, VAT and total) in its own field, usually inside an XML file. Facturae, Spain's own format, also used for public administrations, and UBL, an international standard, are both XML formats.
Required details and storage
Like any invoice, an e-invoice must include:
- its number and date;
- the tax ID (NIF) and address of the issuer and the client;
- a description of the service;
- the taxable base, the VAT rate and amount, and the total.
You have to keep it for at least four years for tax purposes; ask your gestor whether you need to keep it longer.
How e-invoicing between businesses will work
The system works like this:
- the issuer creates the e-invoice in its system;
- it sends the file through a digital channel, such as an e-invoicing platform;
- the client receives it and records it without retyping.
The law provides that platforms from different providers must be interoperable, so that an e-invoice issued on one platform can be received on another; the Royal Decree sets the obligations of these private platforms, which apply from 6 October 2027. The exchange can also go through the public solution managed by the AEAT, which keeps a copy of each invoice: unless you agree another channel with your suppliers, you will receive what they bill you through it. With public administrations, the circuit is different: the e-invoice goes through FACe, the official platform for the public sector, as a Facturae file with an electronic signature.
Reporting the status of each e-invoice
As well as delivering it, the recipient reports its commercial acceptance or rejection and its full payment, with their dates, within four days, not counting Saturdays, Sundays or national holidays. As a freelancer, you will have to do so from 6 October 2029.
Free e-invoicing tools and how to choose one
With a low volume, free solutions can be enough to start.
Free options
- FACe: free and secure, but only for public administrations.
- The AEAT's free app: the Tax Agency offers a free invoicing application designed for professionals and freelancers with few invoices. It is designed for Verifactu compliance, but check whether it will also support e-invoicing between businesses before you rely on it.
- Programs with free plans: limited in documents, users or features, they may be enough for a freelancer.
Compliance checklist for your invoicing tool
Before choosing, check that the tool:
- can support the accepted formats;
- lets you deliver the files to clients and public bodies;
- has its manufacturer's declaración responsable and adds the QR code;
- keeps you informed of the status of each e-invoice;
- lets you export your data if you ever change tools.
How to issue your first e-invoice
The process, from certificate to storage:
- Get your digital certificate (for individuals, the FNMT issues it free of charge).
- Choose a tool that meets the checklist above.
- Set up your tax details and those of your clients.
- Create the e-invoice with the description, amount and VAT.
- For a public administration, sign it electronically from the tool itself.
- Send it: through FACe to a public body, or through the digital channel you agree on with a business.
- Keep it for the required period.
Common mistakes that can invalidate an e-invoice
- Treating signed PDFs as e-invoices: they are not machine-readable.
- Forgetting the electronic signature, or emailing the file, when you work for a public body.
- Using incomplete or incorrect tax details (tax ID, address), which forces you to correct the document.
- Not keeping your invoices for the required period, which can lead to penalties in an inspection.
- Assuming that a system that meets the software requirements already handles e-invoicing: the two are separate.
What happens if you don't comply?
The rules provide for penalties for failing to meet the e-invoicing obligation; check the current amounts with the AEAT or your adviser. Other consequences:
- a public administration may delay payment until you submit the e-invoice properly;
- business clients may ask you to correct invoices that don't comply.
How to prepare for Spain's e-invoicing mandate
You don't need to wait for the final dates. A short compliance checklist:
- list who you bill: businesses, private customers or public bodies;
- ask your provider whether its program is ready for e-invoicing and has its declaración responsable;
- get your digital certificate if you don't have one yet;
- ensure each client's tax ID and address are correct;
- agree with your gestor on when to switch, based on the latest official dates.
If invoicing already takes up a good part of your week, see what paperwork really costs a freelancer.
Clients in France and other EU countries
Spain is not the only country adopting e-invoicing. France has its own mandate, explained in our guide to e-invoicing in France, and the EU's VAT in the Digital Age (ViDA) package will introduce digital reporting, based on e-invoicing, for cross-border trade within the EU. At European level, e-invoicing in public procurement already has a common basis across the European Union: contracting authorities must be able to receive files that follow the European standard on e-invoicing. When a supplier and a buyer are in different countries, that shared standard makes the exchange of data between them easier.
Adapting to e-invoicing is not complicated: with your certificate and a suitable tool, you can prepare today, while there is no pressure.