Mandatory e-invoicing is coming to Spain under Royal Decree 238/2026 — but there is a critical detail that many SMEs and freelancers miss: the 12, 24 and 36-month deadlines have not started yet. Everything depends on a Ministerial Order that is still going through a public consultation process. This guide explains who is affected, when, and what you need to do.
Spain is undergoing three simultaneous regulatory changes in invoicing that affect every business and freelancer. The problem is that many confuse them, mix them up or treat them as one. They are not. The SIF (Invoicing Computer System), VeriFactu and B2B e-invoicing are three distinct concepts, born from three different regulations, with three different objectives and three different timelines. This guide explains each one clearly, with their real deadlines and key differences.
There are two ways to issue an invoice without VAT in Spain: because the transaction is outside the scope of VAT, or because it is within scope but exempt. These are different situations with different fiscal consequences, and confusing them can result in invalid invoices, loss of input VAT deduction rights and problems in a tax inspection. Furthermore, when an exemption applies, the law requires the invoice to state the specific legal basis for that exemption. This guide explains the difference, what exemptions exist and exactly what must appear on the invoice.
If you are a freelancer or run a small or medium-sized business in Spain and have heard about RD 1007/2023, the VeriFactu Regulation or the "Anti-Fraud Law" without quite understanding what it means for you, this article is for you. We are going to explain — without unnecessary technicalities — what Royal Decree 1007/2023 requires, who it applies to, from when, and above all, what concrete steps you can take today to reach 2027 without surprises.