Law 18/2022 of 28 September, known as Crea y Crece, is Spain’s business creation and growth law. It cuts the minimum capital of an SL to €1, pushes company registration through CIRCE and requires businesses and autónomos to issue, send and receive electronic invoices between themselves. That obligation now has a calendar: October 2027 for businesses with turnover above €8 million and October 2028 for everyone else.
The rest of the measures have applied since 2022. E-invoicing took longer: it needed a regulation and a ministerial order. The dates by type of business are in is electronic invoicing mandatory.
The law was published in the BOE on 29 September 2022 and came into force twenty days later. Article 12, on e-invoicing, had deferred effects.
Between businesses: all businesses and professionals must issue, send and receive electronic invoices in their dealings with other businesses and professionals. That includes autónomos and companies. The law sets no size threshold that exempts anyone: what changes is the deadline.
With individuals: sales to consumers are outside, with one exception. Companies providing services of special economic importance must issue electronic invoices to individuals who accept them or ask for them.
Article 2 bis of Law 56/2007, as amended by Crea y Crece, sets six obligations:
The law has no date by itself. Its deadlines run from when the regulation is approved, and that happened in two steps.
From 6 October 2026, 12 months run for businesses with turnover above €8 million the previous year (October 2027) and 24 months for everyone else (October 2028). Autónomos get one extra year to report invoice statuses.
An electronic invoice is a structured message following the European EN16931 data model, in one of these syntaxes: CII, UBL, EDIFACT or Facturae, under article 7 of Royal Decree 238/2026.
The Tax Agency’s public solution uses UBL. If you do not use it, your platform must send it a faithful copy in UBL. Access to the public solution is free, and the Tax Agency will develop a free application or form to issue electronic invoices.
It is often said that Crea y Crece fines up to €10,000 whoever does not use e-invoicing. Article 2 bis.9 provides a warning or a fine of up to €10,000, but for companies that serve the public and do not offer their customers the option of receiving electronic invoices, or do not let them access their invoices.
Neither that paragraph nor Royal Decree 238/2026 sets a specific fine for invoices between businesses. Verifactu penalties are a separate matter: see Verifactu penalties.
Crea y Crece governs the format in which you send invoices between businesses. Verifactu governs the system you issue them from: an unalterable record and a QR code.
They are separate obligations with separate dates. Hacienda announced on 5 October 2026 a postponement of Verifactu to October 2028 that is not in the BOE yet: Verifactu postponed. The detailed comparison is in the difference between Verifactu and electronic invoicing.
Thinking the regulation is still pending. It was published on 31 March 2026.
Thinking it only applies to large companies. It applies to all businesses and professionals. Only the deadline changes.
Attributing the €10,000 fine to invoices between businesses. That paragraph targets other companies.
Mixing it up with Verifactu. They are separate rules.
Treating a PDF as valid. An electronic invoice is a structured message.
What it is: Spain’s business creation and growth law, from 2022.
Measures: SL with €1 capital, CIRCE, single market, financing and e-invoicing between businesses.
E-invoicing dates: October 2027 (above €8 million) and October 2028 (everyone else).
Rules: Law 18/2022, Royal Decree 238/2026 and Order HAC/1028/2026.
Formats: CII, UBL, EDIFACT and Facturae.
Law 18/2022 of 28 September on business creation and growth. It cuts the minimum capital of an SL to €1, strengthens CIRCE, improves the single market, makes financing more flexible and requires e-invoicing between businesses.
On 19 October 2022, twenty days after publication. The e-invoicing article had deferred effects.
October 2027 for businesses with turnover above €8 million the previous year and October 2028 for everyone else.
To all businesses and professionals, autónomos and companies, in invoices with other businesses and professionals. Sales to individuals are outside, except for companies providing services of special economic importance.
CII, UBL, EDIFACT and Facturae, under article 7 of Royal Decree 238/2026.
€1. If capital is below €3,000, at least 20% of profit must go to the legal reserve until reserve and capital reach €3,000.
No. Crea y Crece governs the format of invoices between businesses. Verifactu governs the system they are issued from.
Related: Is electronic invoicing mandatory / Verifactu postponed / Verifactu vs electronic invoicing
