FULL GUIDE · UPDATED MAY 2026

The Crea y Crece Act and mandatory B2B e-invoicing

What is required, who is affected, when and how to prepare without hiring a consultancy. Reading time: ~12 minutes.

verified_user Cláusula legal team
calendar_today Last reviewed: 13 May 2026

Table of contents

  1. 1. Regulatory framework: Law 18/2022 and the European context (ViDA)
  2. 2. Legal obligations: issuance, receipt and reporting
  3. 3. Implementation timeline: key dates
  4. 4. Technical aspects (RD 238/2026): the end of Excel and Word
  5. 5. Comparison: Crea y Crece vs Verifactu
  6. 6. Penalty regime: up to €10,000 in fines
  7. 7. Compliance checklist by professional profile
  8. 8. The 5 most common transition mistakes
  9. 9. Frequently asked questions (FAQ)

1. Regulatory framework: Law 18/2022 and the European context

Law 18/2022, of 28 September (known as the Crea y Crece Act) is the cornerstone of Spain's digital transformation of commercial transactions. Its main goal is to combat late payment and digitise the business ecosystem.

It's not an isolated initiative. It is part of the European ViDA (VAT in the Digital Age) strategy, which aims to harmonise real-time VAT reporting via structured formats such as Facturae or UBL. Issuing plain PDFs will no longer be enough for tax compliance between businesses.

2. Legal obligations: issuance, receipt and reporting

The law doesn't just require you to "send" a file. It establishes a full invoice lifecycle:

3. Implementation timeline

Business segmentDeadline
Revenue > €8 millionOctober 2026
Revenue < €8 millionSeptember 2027
Self-employedSeptember 2027

4. Technical aspects (RD 238/2026)

Royal Decree 238/2026 defines the system architecture. There will be a Public Invoicing Solution managed by the AEAT, coexisting with authorised private platforms.

warning

CRITICAL NOTICE

Using Word, Excel or design tools to issue B2B invoices will no longer be legal. Every invoice must be generated by certified software that guarantees the integrity, conservation and legibility of the XML file.

5. Crea y Crece vs Verifactu

Crea y Crece Act

Regulates the B2B relationship. Requires the exchange of invoices in a structured electronic format between companies and self-employed professionals to monitor payment terms.

Verifactu (RD 1007/2023)

Regulates IT systems. Requires software to send billing records to the AEAT in real time to prevent tax fraud (off-the-books invoices).

6. Penalty regime

Failing to comply with the e-invoicing obligation or failing to report payment statuses carries severe penalties:

€10k
Fines of up to €10,000 per breach. In addition, companies that don't meet payment terms cannot access public grants or aid.

7. Compliance checklist

For SMEs

  • ☐ Audit current software: does it support Facturae/UBL?
  • ☐ Define an XML reception protocol.
  • ☐ Train the admin team on status management.

For self-employed professionals

  • ☐ Drop manual PDFs (Excel/Canva).
  • ☐ Apply for Kit Digital to roll out certified software.
  • ☐ Ensure connection to the AEAT public platform.

For advisory firms

  • ☐ Automate payment-status reconciliation.
  • ☐ Enable integrated communication channels with clients.
  • ☐ Monitor payment-term compliance to avoid fines.

8. The 5 most common mistakes

01

Thinking that sending a PDF by email counts as "e-invoicing" (it doesn't).

02

Ignoring the obligation to report the actual payment date.

03

Thinking "Verifactu" and "Crea y Crece" are the same thing.

04

Not checking whether the software provider is certified under RD 238/2026.

05

Waiting until the last month of the legal timetable to start the technical transition.

9. Frequently asked questions (FAQ)

Does this affect invoices to end customers (B2C)? expand_more
Not directly under the Crea y Crece Act, which is strictly B2B. For B2C, the Verifactu rules on billing records apply instead.
Is it mandatory to use the AEAT platform? expand_more
No. You can use any certified private platform, provided it guarantees free interconnection with the public solution and other platforms.
How do I prove the payment date? expand_more
Through the status messages defined in RD 238/2026 that the recipient must mandatorily send to the issuer or the centralised platform.

Want to know whether your company is ready?

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