Mandatory B2B e-invoicing in Spain (Crea y Crece law) and Odoo
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B2B e-invoicing in Spain becomes mandatory on 6 October 2027 for businesses and professionals with an operations volume above EUR 8 million, and on 6 October 2028 for everyone else. It comes from Law 18/2022 (the "Crea y Crece" law) and is developed by Royal Decree 238/2026 and Order HAC/1028/2026. It is not Verifactu: it is a different obligation with a different calendar. This guide summarises what it requires, who it affects and what you can do today with Odoo.
Last reviewed: 2 November 2026. The dates in this guide come from the AEAT's electronic office, updated on 27 October 2026. Separately, Verifactu keeps 1 January and 1 July 2027 as its legal dates in force; on 5 October 2026 the Ministry of Finance announced its intention to postpone them to October 2028, announced and pending publication, and until it appears in the BOE the 2027 dates apply. Details in deadlines and penalties.
Timeline of the rule
| Milestone | Date | Source |
|---|---|---|
| Business creation and growth law, which extends the duty to issue and send e-invoices to all businesses and professionals | Published 29 September 2022 | Law 18/2022 |
| Regulation of mandatory e-invoicing between businesses and professionals (also amends the 2012 invoicing regulation) | Approved 25 March 2026, published in the BOE on 31 March, in force from 20 April 2026 | Royal Decree 238/2026 |
| Order on the public e-invoicing solution, on which the deadlines depend | Published 5 October 2026, in force 6 October | Order HAC/1028/2026, BOE-A-2026-20587 |
The effective application of the royal decree was conditional on that order, and the deadlines run from its entry into force.
Application calendar
According to the AEAT, counted from 6 October 2026:
| Date | Who | What they must do |
|---|---|---|
| 6 October 2027 | Businesses and professionals with an operations volume above EUR 8 million | Issue, send and receive e-invoices, and report invoice and payment statuses |
| 6 October 2028 | All other businesses and professionals (including freelancers) | Issue, send and receive e-invoices. Legal entities with EUR 8 million or less also report statuses |
| 6 October 2029 | Individuals and income-attribution entities | Report invoice and payment statuses |
The EUR 8 million threshold is based on the operations volume of the previous calendar year, under article 121 of the VAT Law.
What the regulation requires
- Structured invoice. The invoice must be a structured electronic message. A PDF is not enough on its own.
- Invoice statuses. The recipient must report commercial acceptance or rejection and full effective payment, with their dates, within four calendar days (excluding Saturdays, Sundays and national holidays). Without a rejection, the invoice is presumed accepted. Partial payments and assignment are voluntary statuses.
- Two exchange routes. The AEAT public solution, which will offer a free form, or private invoice exchange platforms, or both.
- Private platforms. Among other requirements: ISO/IEC 27001 certification or equivalent, AS2 or AS4 protocols, an advanced electronic signature or seal, and free interconnection between platforms. Those that do not use the public solution must send it a UBL copy of every invoice.
- Transitional PDF period. Those above EUR 8 million must accompany the e-invoice with a readable PDF for twelve months, unless the recipient accepts only the original format.
- Out of scope: simplified invoices (except qualified simplified ones) and operations the Ministry of Economy, Trade and Business excludes by order (art. 4.2 of RD 238/2026). In the Basque Country and Navarra it applies according to their economic agreement.
This text does not cover the penalty regime for this obligation; we have not verified it and do not assume it.
Formats: UBL, CII, EDIFACT, Facturae and EN 16931
Article 7 of the royal decree allows four syntaxes for the invoice: CII, UBL, EDIFACT and Facturae. All must follow the European EN 16931 semantic model. Private platforms must be able to convert the message between all the accepted formats, and the public solution uses UBL. The royal decree's preamble cites Peppol BIS as valid on private platforms because it relies on UBL and EN 16931, although the articles do not mention it.
It is not Verifactu
| B2B e-invoicing | Verifactu | |
|---|---|---|
| Rule | Law 18/2022, Royal Decree 238/2026 and Order HAC/1028/2026 | Law 11/2021 and Royal Decree 1007/2023 |
| What it regulates | Structured format, exchange channel and invoice statuses | How invoicing software must behave (record, hash, QR) |
| Between whom | Between businesses and professionals | Any invoice issued with an invoicing computer system |
| Dates | 6 October 2027 and 2028 (and 2029 for individuals' status reporting) | 1 January and 1 July 2027; October 2028 postponement announced, not in the BOE |
Royal Decree 238/2026 does not mention Verifactu. The link is one of calendar: the Ministry of Finance announced the Verifactu postponement to align it with B2B e-invoicing, but that postponement is not in the BOE. The same company can end up subject to both obligations. If you are also in the SII or a regional territory, read the guide on differences between Verifactu, SII, TicketBAI and Facturae.
What Odoo offers today
The following is what we could verify in Odoo's documentation and public repositories as of 2 November 2026.
| Piece | What it does | Detail |
|---|---|---|
l10n_es_edi_facturae (Odoo) |
Generates and signs Facturae 3.2.2 files | Available on branches 17.0 to 19.0. Odoo's documentation describes it as a module for the central government |
l10n_es_facturae (OCA) |
Generates Facturae; with l10n_es_facturae_face, sending to FACe |
Branches 14.0 to 19.0 (FACe: 14.0 to 18.0). The 18.0 branch is listed as Beta |
UBL and CII export (account_edi_ubl_cii) |
Exports and imports UBL Bis 3, Factur-X (CII) and some national formats; the PDF is embedded in the XML of UBL formats | Formats are chosen per journal. UBL Bis 3 is available for countries on Peppol's EAS list |
Peppol (account_peppol) |
Sending and receiving documents over the Peppol network | Odoo's documentation says registration is free and available in Community, and lists Spain among eligible countries |
What we could not verify: that any of these pieces, on their own, covers the whole of Royal Decree 238/2026, meaning the connection to a private platform or to the AEAT public solution and the reporting of invoice and payment statuses. That is to be expected: the order that starts the clock came into force on 6 October 2026. Ask your partner or provider for their coverage plan in writing.
On editions: the official modules sit in Odoo's public code under LGPL-3, and the documentation does not limit them to one edition; confirm with your partner what you can install and maintain in your case.
How to prepare without waiting
- Work out your date. Did your operations volume exceed EUR 8 million last year? Then it is October 2027; otherwise October 2028.
- Map your flows. Which customers and suppliers exchange invoices with you, and through which channel (PDF by email, portals, Facturae for the public sector).
- Review your Odoo master data. Clean tax IDs, addresses and partner details; rejections almost always start with source data.
- Choose the channel. AEAT public solution, private platform or both, depending on your volume and integrations.
- Ask your Odoo partner how your installation will connect to that channel and how it will record acceptance, rejection and payment.
- Prepare the team. Who reviews received invoices, who reports a rejection and within what time.
And keep it apart from your Verifactu preparation: that one has its own checklist to prepare Odoo.
Can we help?
If you work with Odoo and want to know what is missing for Verifactu and for B2B e-invoicing, at uKodeIT we review your version, modules and invoicing flows. See the Verifactu in Odoo service page or get in touch.
Related guides
Frequently asked questions
When does B2B e-invoicing become mandatory in Spain?
According to the Spanish tax agency (AEAT), on 6 October 2027 for businesses and professionals with an operations volume above EUR 8 million, and on 6 October 2028 for everyone else. Reporting of invoice and payment statuses comes later for individuals and income-attribution entities: 6 October 2029.
Is it the same as Verifactu?
No. Verifactu (Royal Decree 1007/2023) sets how invoicing software must behave: tamper-proof records, hash and QR. B2B e-invoicing (Law 18/2022 and Royal Decree 238/2026) sets the structured invoice format, the exchange channel and the reporting of statuses. They are two obligations with different calendars.
Which e-invoice formats does the regulation accept?
A structured message in CII, UBL, EDIFACT or Facturae, all following the European EN 16931 semantic model. A PDF on its own does not count as an e-invoice.
Does Odoo comply with mandatory e-invoicing?
Odoo has related pieces: the l10n_es_edi_facturae module, UBL and Factur-X (CII) export, and Peppol sending. But as of 2 November 2026 we have found no official Odoo or OCA documentation declaring full coverage of Royal Decree 238/2026 (platform or public solution, payment statuses). Ask your partner.
Do freelancers have to issue e-invoices?
Yes, between businesses and professionals: from 6 October 2028, according to the AEAT calendar. The AEAT will provide a free application to issue and manage these invoices. Simplified invoices are outside the scope, except qualified simplified ones.
Do Peppol and private platforms count?
The regulation provides two routes, the AEAT public solution and private exchange platforms, which must meet requirements such as ISO/IEC 27001 certification. The preamble cites Peppol BIS as valid on private platforms, but the articles do not include it. Confirm with your provider how it meets each requirement.