Mandatory B2B e-invoicing in Spain: the receiver side

By Nicolau Matarrodona, founder · Published 3 May 2026 · Updated 24 October 2026

In Spain, businesses and professionals with a volume of operations above €8 million must send and receive their business-to-business invoices as structured e-invoices from 6 October 2027, and everyone else from 6 October 2028. The receiver must also report acceptance or rejection and full payment of each invoice to the supplier within four calendar days, excluding Saturdays, Sundays and national holidays, and report rejection and full payment to the Tax Agency's public service. What does not change for accounts payable is the core control: a well-formed e-invoice can still charge more than was ordered or received, so matching it against the purchase order and the delivery note is still needed.

Sources checked on 24 October 2026 (in Spanish): Royal Decree 238/2026 of 25 March (Official State Gazette, BOE, 31 March 2026), Order HAC/1028/2026 of 2 October (BOE, 5 October 2026, in force on 6 October 2026) and the Spanish Tax Agency implementation calendar (updated 13 October 2026). This guide is informative and is not tax advice.

The dates: when you must receive e-invoices

Royal Decree 238/2026 implements the B2B e-invoicing obligation created by Law 18/2022 on business creation and growth. Its deadlines started counting on 6 October 2026, when Order HAC/1028/2026, which regulates the Tax Agency's public e-invoicing service, came into force.

Who	Send and receive e-invoices	Report statuses (rejection and payment)
Businesses and professionals with a volume of operations above €8 million	6 October 2027	6 October 2027
Other legal entities (companies of €8 million or less)	6 October 2028	6 October 2028
Individuals (self-employed) and income-attribution entities of €8 million or less	6 October 2028	6 October 2029

The full calendar, with each milestone linked to its source, is in the e-invoicing calendar 2027–2029 (in Spanish).

What changes if you are the one receiving the invoices

Topic	Until now	Under Royal Decree 238/2026	Article
Format	PDF by email, paper, supplier portals	Structured message based on the EN 16931 semantic model, in UBL, CII, EDIFACT or Facturae syntax	Art. 7.1
Channel	Whatever the parties agree	A private exchange platform, the Tax Agency's public service or both; without an agreement to receive through a private platform, the public service is assumed	Art. 6.1
Entry point	Does not exist as such	Receivers using a private platform must publish their invoice entry point(s)	Art. 6.3
Acceptance or rejection	Internal; the supplier does not always know	The issuer is informed of commercial acceptance or rejection and its date	Art. 10.1
Payment	The supplier sees it in the bank	Full effective payment and its date are reported to the issuer and to the public service, together with the due date	Arts. 10.1 and 12
Deadline for those reports	—	Four calendar days, excluding Saturdays, Sundays and national holidays, from the date the status occurs, for reports to the issuer and for payment reported to the public service; the decree sets no specific deadline for reporting a rejection to the public service	Arts. 10.3 and 12.3
Invoices not rejected	—	Presumed accepted if there is no rejection and no later corrective invoice	Art. 12.1
Transition	—	Issuers above €8 million attach a PDF to each e-invoice for twelve months, unless the receiver accepts the original format only	Second transitional provision

Acceptance, rejection and payment within four days

Article 10.1 requires the receiver to inform the issuer of commercial acceptance or rejection with its date, and of full effective payment with its date. Article 12.1 also requires the receiver to report full payment or rejection to the public service, whatever channel the invoice came through, and Article 12.3 adds the due date. Partial payments, partial acceptance or rejection and assignment of the invoice to a third party may be reported, but are optional (Art. 10.2).

Reports to the issuer must be sent within four calendar days excluding Saturdays, Sundays and national holidays, counted from the date the status occurs: from the acceptance or rejection decision, or from the payment (Art. 10.3). Payment reported to the public service has the same deadline from the effective payment date (Art. 12.3); for a rejection reported to the public service the decree sets no specific deadline. Regional and local holidays are not excluded. Two effects for accounts payable:

An invoice that is not rejected is presumed accepted. If the price later turns out to be wrong, the route is a corrective invoice from the supplier, not a late rejection.
The due date and the payment date of each invoice are reported to the public service. Supplier payment terms are set by Article 4 of Law 3/2004 on late payment: 30 calendar days from receipt of the goods or service by default, and never more than 60 by agreement.

Want to see it with your own invoices? Request a demo with your own invoices

The transition PDF: the same invoice twice

Under the second transitional provision of Royal Decree 238/2026, for the twelve months after the decree takes effect, businesses with turnover above €8 million attach to each e-invoice a PDF that ensures its legibility, unless the receiver voluntarily and expressly accepts the original format only. According to the Tax Agency calendar, that obligation starts on 6 October 2027 for this group. The PDF is sent by any means and never to the public service.

For the receiver, the PDF is a readable copy of an invoice that has already arrived in structured form. If the PDF comes in through the invoice mailbox and the e-invoice through the platform, the same document appears twice. It should be treated as a possible duplicate and linked to its e-invoice, not booked as a second invoice. See the types of duplicate invoice and how to stop them.

For a year two kinds of supplier will also coexist: those above €8 million will send e-invoices from 6 October 2027, while those at €8 million or less are not obliged until 6 October 2028. A group receiving invoices from hundreds of suppliers will have a mixed inflow of structured invoices, structured invoices with a PDF and PDF-only invoices during that period.

Why you still need the purchase order and the delivery note

E-invoicing guarantees that the invoice arrives structured, with the mandatory data and through a traceable channel. It does not check that the price matches the purchase order or that the quantity matches the delivery note signed by the warehouse. Checking price and quantity remains the receiver’s job, and now it has a deadline: a rejection must reach the supplier within four days of the decision.

Worked example in euros (synthetic data)

Example built for this guide with round figures; it does not correspond to any real company.

A supplier issues a UBL e-invoice, valid in format, for 1,000 units at €4.20 each before tax. The purchase order set €4.00 and the signed delivery note records 950 units received.

Check	Calculation	Difference
Price (invoice vs PO)	(€4.20 − €4.00) × 1,000 units invoiced	€200.00
Quantity (invoice vs delivery note)	(1,000 − 950) units × €4.00 PO price	€200.00
Overbilled against what was received at the agreed price	1,000 × €4.20 − 950 × €4.00	€400.00

Format validation passes this invoice. Without line-by-line matching against the PO and the delivery note, the €400 is paid and the invoice is presumed accepted. With matching, the invoice is held before payment and someone decides whether to reject it or ask for a corrective invoice. The method is explained in how three-way matching works line by line and in six cases of invoices that do not match the delivery note.

Checklist for accounts payable before 6 October 2027

Know which tier each group company is in. The threshold is a volume of operations of €8 million; within a group each company may fall in a different tier.
Choose the receiving channel: private platform, public service or both.
Publish your entry points if you receive through a private platform, and tell your suppliers.
Classify suppliers by tier to know who will send e-invoices in 2027, who in 2028 and who will also send the transition PDF.
Define who decides a rejection and where. The four-day clock for telling the supplier starts when the decision is made; the decision has to be recorded with its date and reason.
Hold the due date of each invoice, compliant with Article 4 of Law 3/2004.
Connect payment and its report: treasury or the ERP pays; the full payment has to be reported within four days.
Prepare duplicate control for the e-invoice and its accompanying PDF.
Keep matching against PO and delivery note for every invoice, whatever its format.

Not to be confused with Verifactu

Verifactu regulates the invoicing software used to issue invoices and binds the issuer, not the receiver. B2B e-invoicing regulates the format and exchange between businesses and does require the receiver to report statuses. See what Verifactu means for the company that pays.

What ininvoice does today and what it does not

ininvoice is receiver-side accounts payable software. It does not issue invoices, it is not an e-invoice exchange platform and it does not report statuses to the issuer or the public service.

Today: it reads supplier invoices in PDF, image, scan or photo from the mailbox or by manual upload, line by line; matches each line against the purchase order and the delivery note with the tolerance set by the organisation (by default it holds a line exceeding €1.50 or 2 %); holds possible duplicates; checks base, VAT, withholding and tax ID; and lets you approve, reject or ask for clarification from the dashboard, with the history of each invoice.
In development: direct reading of structured e-invoices (XML). No date is committed.
Does not: report acceptance, rejection or payment to the public service or the supplier; that is done by the e-invoicing platform or the public service. The approve-or-reject decision taken in ininvoice tells you what to report and when.

Frequently asked questions

When must Spanish companies receive B2B e-invoices?

From 6 October 2027 for businesses and professionals with a volume of operations above €8 million, and from 6 October 2028 for everyone else, according to the Spanish Tax Agency calendar applying Royal Decree 238/2026 and Order HAC/1028/2026.

Which e-invoice formats are valid in Spain?

Article 7.1 of Royal Decree 238/2026 allows CII, UBL, EDIFACT and Facturae, all based on the EN 16931 data model. The Tax Agency public service works in UBL. The preamble considers Peppol BIS valid on private platforms.

What does the receiver of an e-invoice have to report?

To the issuer: commercial acceptance or rejection and full effective payment, with their dates (Art. 10.1). To the public service: rejection or full payment and the due date (Art. 12). Partial payments are optional.

What happens if I do not reject an e-invoice?

Article 12.1 of Royal Decree 238/2026 presumes the invoice accepted if there is no rejection and no later corrective invoice.

Does e-invoicing replace three-way matching?

No. E-invoicing ensures format and channel, not that price and quantity match the purchase order and the delivery note. That check is still the receiver’s job, now with a deadline to reject.