Peppol BIS and mandatory B2B e-invoicing in Spain 2026: what your AP team must do

There's confusion. Questions such as “Does Peppol replace Verifactu?” or “My advisor tells me to migrate to FacturaE, but my ERP doesn't support it” mix up different things.

The problem isn't the rule. It's that the conversation mixes Crea y Crece, Verifactu, FacturaE, Peppol and Access Points. Too many names for a single decision: your AP system must read structured XML before the mandatory dates.

This article is for Finance Directors and controllers in SMEs. It explains what Spanish Royal Decree 238/2026 requires, how FacturaE and Peppol BIS differ, and a concrete checklist to prepare your AP stack.

What Spanish Royal Decree 238/2026 requires

The legal base starts in September 2022. The Law 18/2022 on the creation and growth of companies (known as Crea y Crece) amends article 12 of Law 56/2007 and introduces the obligation to issue e-invoices in all commercial relationships between companies and professionals in Spain.

The detailed regulation, however, wasn't published then. A Royal Decree was needed to set formats, platforms, deadlines and technical obligations. That Royal Decree is Royal Decree 238/2026, published in the BOE on 31 March 2026. Order HAC/1028/2026 completes the technical detail.

Key points for the Finance Director:

• Scope. All B2B invoices in Spanish territory. Not B2C.
• Mandatory structured format. Signed PDF is not enough. Interoperable structured XML.
• Phased timeline. Issuing and receiving from 6 October 2027 for companies with turnover above EUR 8M and from 6 October 2028 for everyone else. Status reporting starts on 6/10/2027 (large companies), 6/10/2028 (other legal persons) and 6/10/2029 (natural persons). Source: AEAT implementation calendar.
• Public repository. AEAT public solution will receive a copy, alongside certified private platforms as intermediaries.
• Payment status. Recipients will report status (accepted, rejected, paid). Late-payment control under Spanish Law 3/2004.

If your company processes supplier invoices, you will receive XML before your deadline. That's the real operational problem.

FacturaE vs Peppol BIS: the table you must have clear

Royal Decree 238/2026 admits four syntaxes (article 7.1): UBL, CII, EDIFACT and Facturae. Two of them dominate the conversation in Spain. They aren't rivals, they are different tools that can coexist.

Aspect	FacturaE	Peppol BIS 3.0
Origin	Spain national (MINHAC / AEAT)	European (OpenPeppol, historical Nordic roots)
Scope	Spain, historically B2G (FACe)	Cross-border, 32+ EU countries and growing
Schema	Proprietary XML facturae 3.2.x (MINHAC XSD)	UBL 2.1 XML compliant with EN 16931
Entry point	FACe (B2G), private platforms	Certified Peppol Access Point (4-corner network)
Conversion	Convertible to/from Peppol with mapper	Convertible to/from FacturaE with mapper
Status under RD 238/2026	Admitted syntax (art. 7.1)	Uses UBL, one of the syntaxes admitted by art. 7.1 on the EN 16931 model

In practice, serious platforms handle both and convert the payload between formats. The right question is not "Peppol or FacturaE?" but does your AP system read structured XML?. If yes, the format is resolved by configuration.

Why it matters for accounts payable

Your current flow is probably: supplier sends PDF, your team downloads it, OCR processes it, someone reviews, then it goes to accounting. OCR introduces variability: misread numbers, merged lines, totals off by a comma.

With structured XML, that friction disappears. Each field comes labeled: InvoiceLineQuantity, PriceAmount, TaxableAmount. No interpretation.

Three day-to-day changes:

1. More reliable extraction. In a structured XML each data point arrives in its labeled field; nothing has to be interpreted from an image.
2. Three-way matching becomes more reliable. Comparing an invoice line against a PO line is comparing fields of the same type. Read the three-way matching guide.
3. Exceptions go down. Fewer capture errors, less manual review.

The risk: if your system only processes PDF, you'll receive XML that your team will open in a viewer and re-key by hand. You lose all the advantage of the structured format.

Touchless AP advantages under Peppol/FacturaE

Touchless accounts payable is the share of invoices that enter and reconcile without anyone having to correct, re-key or chase them. In ininvoice a person still approves each one.

When input moves from PDF to structured XML, fewer invoices need a correction. Not because your matching engine changes: because the data arrives clean.

Operational translation: every invoice that arrives with clean structured data is one fewer reading error to find and fix before approval.

Risks of not adapting on time

I'll leave fines to your advisor. Here I focus on operational risk:

• Double capture. You receive XML, someone opens it and re-keys it in the ERP. 8-15 minutes per invoice. With 500/month, that's 60-120 hours lost.
• Loss of structured data. Lines, discounts and PO references come structured, but your system only stores totals. Goodbye line-by-line matching.
• Contradiction with Verifactu. Verifactu (issuance) and B2B e-invoicing (receipt) are different but complementary. Mixing standards confuses the team.
• Suppliers ahead of schedule. Some large ones already issue XML voluntarily. If you're not ready, you receive notifications you can't process.

Peppol Access Point vs intermediary platform

For Peppol you need an Access Point: a provider certified by OpenPeppol that connects your company to the 4-corner network. FacturaE doesn't need one: it runs on the AEAT public platform, FACe (B2G) or certified private platforms.

Option	Pros	Cons
Own Peppol Access Point	Full control, minimal latency, no intermediary	High cost, complex certification, only large companies
Shared Access Point	Reasonable cost, technical support, ready to use	Provider dependency, limited SLA
Certified intermediary platform	Covers FacturaE + Peppol in a single contract, auto-conversion	Less control, volume pricing

For an SME with 200-2,000 invoices/month, a certified intermediary platform is the rational choice. It covers both formats, handles conversion and avoids direct certification.

How to prepare your AP stack: concrete checklist

Action needed before 6 October 2027 if any company in your group has turnover above EUR 8M, and before 6 October 2028 otherwise.

1. Channel inventory. List mailboxes, supplier portals and folders where invoices arrive today.
2. Top 50 suppliers audit. Ask them when and in what format (FacturaE, Peppol BIS or own platform).
3. AP system capability. Does it read FacturaE XML? Peppol UBL? If not, schedule upgrade.
4. Entry channel. Intermediary platform vs shared Access Point. Depends on volume and cross-border.
5. Field mapping. Descriptions, product codes and PO references consistent between supplier, AP and ERP.
6. Transition policy. While PDF + XML coexist, set clear rules on which flow goes where.
7. Test with a real supplier. Request an XML invoice before the legal deadline and verify processing.
8. Communication with advisor. Lock the applicable calendar, especially near the EUR 8M threshold.
9. Plan B. What if your Access Point goes down 4 hours at month-end close?

Compatibility with Spanish ERPs in 2026

Support status as of April 2026:

• Holded. Native FacturaE for issuance. Receipt and Peppol per plan.
• Sage 50 / Sage 200. E-invoicing modules with FacturaE. Peppol via partner.
• A3 Innuva. FacturaE in accounting modules. Peppol BIS via intermediary platform.
• Microsoft Dynamics 365. UBL/Peppol European and FacturaE via ES localization.
• Odoo / SAP / Oracle. Standard coverage of both formats.

Pattern: no ERP covers the whole flow (receipt + reading + matching + posting) without a specialized AP layer. E-invoicing is just the input; matching, duplicates and variances remain the AP stack's job.

Where ininvoice fits

ininvoice is an AP layer between your mailbox and the ERP. What we cover:

• Reading of PDF, image and scanned invoices from the mailbox; reading FacturaE and Peppol XML is in development.
• Line-by-line three-way matching with a tolerance set by your organisation (by default 2% or EUR 1.50 per line, OR mode: a line is flagged if it exceeds either limit).
• Duplicate detection and tax checks.
• Export of invoices approved by a person as CSV or Excel importable into the ERP (Holded, Sage, A3).

We are not an ERP or an issuer. We cover receipt + matching, which is where structured XML creates the most value. For issuance, keep your usual ERP or platform.

Frequently asked questions

Is Peppol or FacturaE mandatory?

RD 238/2026 requires an interoperable structured format, doesn't impose just one. FacturaE is national and Peppol BIS provides EU compliance. Most certified platforms support both.

When does it take effect for my company?

Depends on your turnover. Above EUR 8M, from 6 October 2027; otherwise, from 6 October 2028, according to the AEAT implementation calendar that applies Royal Decree 238/2026.

What if my supplier keeps sending PDF after the deadline?

The supplier is non-compliant, not you. But the operational cost is on you. Communicate deadlines well in advance.

Do I need my own Peppol Access Point?

Only for large volumes. For 200-2,000 invoices/month an intermediary platform covers Peppol and FacturaE in a single contract.

Are Verifactu and B2B e-invoicing the same?

No. Verifactu is the issuer's submission of records to AEAT. B2B e-invoicing is the structured format between issuer and recipient. Complementary, not equivalent.

Does Peppol BIS work for suppliers outside Spain?

Yes. It's interoperable across 32+ European countries. It guarantees a common format with Portugal, France, Italy or Germany.

Conclusion

RD 238/2026 changes the front door of your AP chain. PDF goes out, structured XML comes in. The question is not if it will happen, but whether your system will be ready when your suppliers start sending it.

Three takeaways:

1. FacturaE and Peppol BIS coexist. You don't have to choose; your platform must cover both.
2. Structured XML means fewer reading errors without touching the matching engine.
3. The dates are 6 October 2027 for companies with turnover above EUR 8 million and 6 October 2028 for everyone else, according to the AEAT calendar. Always verify with BOE and your tax advisor before locking internal dates.

Related content

• Three-way matching: what it is and how it works
• Touchless accounts payable: how to measure and raise it
• How to detect duplicate invoices before paying
• Verifactu and AP: why it forces a rethink