When the e-invoicing clock starts
Royal Decree 238/2026 regulates e-invoicing between businesses. The months do not start until the ministerial order on the public solution is in force.
12 months or 24, and the clock is stopped
The period is 12 months for anyone whose turnover exceeded €8 million and 24 months for everyone else. That clock starts only when the ministerial order on the public solution is in force. On 26 September 2026 that order was not in the BOE. A draft had pointed at 1 October 2026, and that reference is not a legal date.
- Over €8 million turnover: 12 months.
- Everyone else: 24 months.
- The start is the order in force, not the draft.
It is not the VeriFactu calendar
This rule does not replace the billing-system dates. In the portfolio they are two columns: VeriFactu on one side and, once the clock exists, e-invoicing between businesses. The systems context is in VeriFactu for accounting firms.
Common questions
Is 1 October 2026 the start date?
No. It appeared in a draft. On 26 September 2026 the ministerial order was not in the BOE, and without that order in force the period does not run.
Are the 12 and 24 months already running?
No, while the ministerial order on the public solution is not in force.
Official sources
Informational text reviewed on 26 September 2026. It is not tax advice and does not replace the Spanish Tax Agency or your accountant. Deadlines, rates, and forms can change.