E-invoicing: the clock is set to start on 1 October 2026 — what a Canary SME must do before October 2027 and 2028

A boat-trip operator in Corralejo invoices the hotels that sell its excursions, a Caleta de Fuste builder invoices a developer, a Costa Calma consultant invoices a Spanish SL: three ordinary businesses, three sets of invoices that will have to change shape within two years. The law that makes business-to-business invoices electronic is from 2022; the regulation that gives it a body arrived in March 2026; and the ministerial order that starts the clock is, as we write on 2 September 2026, still a draft with an entry-into-force date of 1 October 2026 printed on it. This is the calendar that follows from those three texts, what the obligation actually consists of, and what a Canary SME should do this autumn rather than next.

What the obligation is

The Crea y Crece law rewrote article 2 bis of the information-society Act: «all entrepreneurs and professionals must issue, send and receive electronic invoices in their commercial relations with other entrepreneurs and professionals», and issuer and recipient «must provide information on the invoice's states» (Ley 18/2022, art. 12). The regulation of 25 March 2026 (Real Decreto 238/2026, published on 31 March) draws the perimeter:

• Who. Anyone obliged to issue invoices under the invoicing regulation, for operations whose recipient is a business or professional with its seat, a permanent establishment or its domicile in Spain (art. 3). The Canary Islands are inside that perimeter: the IGIC Act sends island businesses to «the general rules governing the duty to issue and deliver invoices» (Ley 20/1991, art. 59.1.b), which are the same invoicing regulation. An IGIC invoice to a Spanish business is an electronic invoice from the same dates as an IVA one.
• Who not. Invoices to consumers stay outside; so do simplified invoices — the tickets of a bar or a shop — unless they are the qualified kind that carries the customer's tax number for deduction (art. 4). And so does the German tour operator or the British agency that buys from you: the counterparty must be established in Spain for the duty to bite, so an export invoice is issued as it is today.
• What. An invoice in a structured, machine-readable message that follows the European semantic model EN 16931, in one of four syntaxes: UBL, CII, EDIFACT or Facturae (art. 7); Peppol BIS messages count because they are UBL. A PDF, however neat, is not an electronic invoice under this regulation — it is a picture of one.

The system: platforms and the public solution

Invoices will travel through a «Spanish e-invoice system» made of private exchange platforms and one public solution (art. 5). The platforms must interconnect with each other free of charge when a customer asks, and must be able to convert between all the admitted syntaxes; an issuer can never be forced to use the recipient's platform, and recipients may ask for copies of their invoices for four years at no cost (Ley 56/2007, art. 2 bis, as amended).

The public solution is the AEAT's: free, voluntary, in UBL, and it must be online at least two months before the first company is obliged to use e-invoicing (arts. 11 and DA 5ª). Every invoice in it carries a unique code built from the issuer's NIF, the invoice number and series and the date, and the solution admits an invoice only if the issuer's and the recipient's NIFs are correctly informed — a detail that will punish untidy customer files. Businesses that prefer a private platform must send the public solution a faithful copy of each invoice in UBL at the moment they issue it. In plain terms: from the day your obligation starts, every invoice you send to another Spanish business will sit in a database at the AEAT, whichever route it took.

The states: your customers will report when they pay you

The part of the reform that changes business behaviour is not the format but the feedback. The recipient of an electronic invoice must inform the issuer of at least two states — commercial acceptance or rejection, with its date, and full effective payment, with the date the money actually reached the supplier (art. 10) — and must communicate the payment, or the rejection, to the public solution whatever platform it uses; an invoice neither rejected nor corrected is presumed accepted (art. 12). Partial acceptance, partial payment and the assignment of the invoice to a third party may be reported voluntarily. The regulation says why in its own preamble: to let the administration «calculate and monitor the payment terms of invoices» — the sixty-day ceiling of the late-payment Act stops being a rule nobody measures.

For self-employed people and other individuals below €8 million of turnover the states are voluntary for the first twelve months after their own start date and mandatory afterwards (DT 3ª). For companies of any size they arrive with the invoice itself.

The calendar, as it stands

The regulation entered into force on 20 April 2026 but takes effect only from the day the ministerial order regulating the public solution enters into force (DF 4ª; Ley 18/2022, DF 8ª). Hacienda published its draft order on 16 April 2026, with consultation until 8 May and a final provision that fixes 1 October 2026 as the entry into force; as of 2 September the order has not appeared in the BOE. On that draft date the clock runs like this:

• 1 October 2027 — businesses whose volume of operations exceeded €8 million in the previous calendar year, measured as the VAT Act measures it: issue and receive e-invoices, report states. For their first twelve months they must attach a PDF to each e-invoice for legibility, unless the recipient expressly accepts the raw format (DT 2ª).
• 1 October 2028 — everyone else: every SL, every self-employed professional, every community-of-owners administrator invoicing another business. Individuals below €8 million report states from 1 October 2029.
• Subcontractors already invoicing public-sector contracts through FACeB2B have twenty-four months from the order to move to the new system (DT 1ª).

If the order slips to November or to January, every date above slips with it by the same number of days; the twelve and twenty-four months are counted from the order, not from a calendar year. Two dates do not depend on the order at all: VeriFactu, the rule that makes your invoicing software record every invoice — consumer invoices included — in a way the AEAT can check, applies from 1 January 2027 to companies and from 1 July 2027 to the self-employed and everyone else, as our VeriFactu piece explains. So the real sequence for a small Canary company is VeriFactu first, e-invoicing a year and a half later, with the same software ideally doing both.

What to do this autumn

• Count. How many invoices a year go to Spanish businesses, and who produces them — you, your accountant, a program, a marketplace. That number decides whether the free public solution is enough or a platform earns its fee.
• Ask your software vendor two questions in writing. Will it be VeriFactu-compliant by January or July 2027? Will it produce EN 16931 invoices and either connect to the public solution or to a registered platform by your e-invoicing date? A vendor without dated answers is a vendor to leave.
• Clean the customer file. Every Spanish business customer needs a correct NIF and address in your system now, because the public solution will refuse an invoice without both NIFs and a platform will bounce it.
• Prepare to receive as well as to send. The duty is symmetrical: your suppliers' e-invoices will arrive through the system, and you will have to report their states. Someone in the business must own that inbox.
• Look at your payment terms. From your start date the AEAT will hold the invoice date and the payment date of everything you owe and everything you are owed. A company that pays at ninety days will be visible as one.
• Keep the tickets simple. If most of your sales are simplified invoices to consumers, the e-invoice reform touches only your business-to-business tail; VeriFactu, not this regulation, is your 2027 project.

The Act's own sanction is modest — a warning or a fine of up to €10,000 for a business that, being obliged, does not offer electronic invoices (Ley 56/2007, art. 2 bis.9) — and the VeriFactu penalties are the ones with teeth, up to €50,000 a year for non-compliant software. The real cost of being late is commercial: a large customer that must report your invoice's states will not accept a PDF from you after October 2027.

Where we come in

Our accounting desk in Caleta de Fuste and Costa Calma runs the audit above with you — invoice count, software questions, customer file, receiving process — and then keeps both calendars, VeriFactu and e-invoicing, on your behalf as the dates firm up. See accounting advisory and corporate compliance, or book a consultation — we reply within one business day.

Common questions

My business is in Fuerteventura and invoices with IGIC, not IVA. Does this apply to me?
Yes. The e-invoicing duty follows the invoicing regulation, and the IGIC Act sends Canary businesses to the same general rules on issuing invoices. An IGIC invoice to a business established in Spain becomes electronic on the same dates as a mainland IVA invoice; the tax on it does not change.

Is a PDF sent by e-mail an electronic invoice?
No. The regulation requires a structured message following EN 16931 in UBL, CII, EDIFACT or Facturae. The only role left for the PDF is transitional: companies above €8 million must attach one to each e-invoice during their first twelve months, for legibility.

What if my customer is a German or British company?
The duty applies only when the recipient has its seat, a permanent establishment or its domicile in Spain. Invoices to foreign businesses are issued as today, whichever format they prefer; your Spanish customers are the ones that will require the electronic format.

When exactly do I have to start?
Twelve months after the ministerial order enters into force if your turnover exceeded €8 million last year, twenty-four months otherwise. On the draft's date of 1 October 2026 that means 1 October 2027 and 1 October 2028; if the order is published later, the dates move with it. VeriFactu's 1 January and 1 July 2027 do not move.

Facts verified in September 2026 (Law 18/2022, article 12 and eighth final provision; Law 56/2007, article 2 bis; Royal Decree 238/2026, articles 3, 4, 5, 7, 10, 11 and 12, transitional provisions 1 to 3, fifth additional provision and fourth final provision; the draft ministerial order on the public e-invoicing solution published by Hacienda on 16 April 2026, sole final provision; the BOE's daily summaries checked through 2 September 2026; Law 20/1991, article 59; Royal Decree 1007/2023 and Royal Decree-law 15/2025 for the VeriFactu dates). Dates conditional on the ministerial order are marked as such; your own obligations depend on your turnover and your customers.