TL;DR
- Spain has two invoice deadlines, not one. The general rule is to invoice at the moment of the transaction – but where your customer is a business or professional, you have until the 15th of the month following the one in which VAT became due.
- That B2B rule is in Article 11 of Real Decreto 1619/2012 and has been unchanged since 2013.
- Verifactu did not touch it. Verifactu changed what happens to the record at the moment of issue, which affects backdating, not scheduling.
- Remote Work Europe verified all three paragraphs of Article 11 against the consolidated text at the BOE on 9 September 2026.
Disclaimer: This article provides general information only and does not constitute tax or legal advice. Individual circumstances vary, and how the rules apply to your particular arrangement is a question for a qualified gestor or asesor fiscal.
We’ve been reading a lot of content about Spanish invoicing that quotes ONE sentence of the regulation. There are three, and the second one is the one that governs most freelance work.
I hit this in August. I invoice monthly for a continuing service, and I do it on the last Friday of the month. In August the last Friday was the 28th, for a month that ran to the 31st. A reminder had landed in my inbox saying invoices must be issued on the same date the service is provided, and I spent an unhelpful afternoon wondering whether I had been doing it wrong for two years.
I had not. But working out why took reading the actual regulation rather than the summary, and what I found is worth more than the answer to my own question. And it matters for all of us with Verifactu implementation pending, so here’s what I found out:
When do you actually have to issue an invoice in Spain?
Article 11 of Real Decreto 1619/2012, the Reglamento de facturación, sets two deadlines. The general rule is that invoices must be issued at the moment the transaction is carried out. The exception, in the very next paragraph, is that where the recipient is a business or professional acting as such, the invoice must be issued before the 16th of the month following the month in which the VAT on that transaction became due.
In the original:
1. Las facturas deberán ser expedidas en el momento de realizarse la operación.
No obstante, cuando el destinatario de la operación sea un empresario o profesional que actúe como tal, las facturas deberán expedirse antes del día 16 del mes siguiente a aquél en que se haya producido el devengo del Impuesto correspondiente a la citada operación.
If you invoice businesses, and most freelancers in Spain do, the second paragraph is your rule. Work delivered in March can be invoiced any time up to 15 April. Work delivered on 1 March and work delivered on 31 March share the same deadline, because the deadline attaches to the month, not the day.
This matters because the general rule, read alone, sounds much stricter than the regime actually is – and it is the version that circulates.
What is the devengo, and why does the deadline hang off it?
The devengo is the moment the VAT liability arises, which is not always the moment you get paid or the moment you finish the work. For a one-off service it is normally when the service is performed. For a continuing service billed periodically, it is normally taken at the end of each billing period. For goods it is when they are made available to the buyer.
The deadline in Article 11 counts from the month containing the devengo. So establishing when the devengo falls is the whole game, and it is also the part that gets genuinely difficult once your income stops looking like tidy monthly projects.
Remote Work Europe maintains guides on the wider autónomo system in Spain and on what the 2026 contribution changes mean, both of which sit underneath this.
Did Verifactu change the invoice date rules?
No. Article 11 was last amended in 2013 and Verifactu did not touch it. What Verifactu changed is what happens to the record at the moment of issue: a certified billing system generates a signed, chained, timestamped entry that cannot be altered afterwards.
The practical effect is on backdating, not on scheduling. Before, you could produce an invoice on 10 September and put 31 August on the face of it. Under Verifactu the record carries the real generation timestamp, so the issue date and the record can no longer drift apart.
That is almost certainly what the stricter-sounding reminders are reaching for. Do not date invoices earlier than you actually issued them is good advice and a real change. Compressed into a single sentence, it comes out as invoice on the day of the work, which is a different claim and is not what the regulation says.
We have covered the mechanics of Verifactu itself elsewhere: what it is and who it applies to, the rollout and preparation, and how corrections work once an invoice is inside the system.
What about the cash-basis VAT scheme?
A third paragraph, added in 2013 and in force since 1 January 2014, covers the régimen especial del criterio de caja. Under the cash-basis scheme, invoices must be issued at the moment the operation is carried out – except, again, where the recipient is a business or professional, in which case the same before-the-16th-of-the-following-month deadline applies.
So the B2B extension survives the cash-basis scheme. If you are on criterio de caja and invoicing businesses, your deadline works the same way.
When is the devengo on a retainer, a commission, or a referral fee?
This is where the tidy answer runs out, and it is the part nobody writes about because it does not reduce to a rule.
Three arrangements I am currently living with, none of which look like a project with a delivery date:
A monthly retainer for a continuing service. The service does not finish on a particular Tuesday. It runs. If the devengo is taken at period end, invoicing on the last Friday of the month is fine when the last Friday is the 30th, and raises a question when it is the 28th of a 31-day month, because three days are then invoiced before they are delivered. For a fixed monthly fee this is ordinary commercial practice. It is still the right question to ask your gestor rather than to assume.
Affiliate commissions that accrue daily and pay on a threshold. Commission builds up across weeks, the merchant reports monthly, and payment triggers when the balance clears a minimum. There is no single moment that obviously is the operation. Different advisers place the devengo in different spots.
A referral fee payable years after the introduction. I have an arrangement under negotiation where a fee could fall due long after the work that earned it. The introduction happened once; the money arrives on someone else’s timetable.
None of these is exotic. They are what a modern freelance income actually looks like, and the Article 11 deadline was written for a world of discrete transactions. If your income has this shape, the answer is a conversation with an asesor, not a blog post – including this one.
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Does mandatory B2B e-invoicing change the deadline?
It does not change when you must issue. It changes the form the invoice takes and how it travels. Real Decreto 238/2026, published on 31 March 2026 and in force from 20 April, inserted Article 8 bis into the same regulation, making electronic invoicing obligatory where the recipient is a business or professional based in Spain.
That obligation is not yet enforceable on anybody. Effective application is deferred and counted from the entry into force of a ministerial order developing the public e-invoicing platform, which the Agencia Estatal de Administración Tributaria has been tasked with building. From that order, businesses turning over more than 8 million euros have twelve months, and everyone else – which is where autónom@s sit – has twenty-four. For individuals and income-attribution entities, the Agencia Tributaria puts the obligation to report invoice status at thirty-six months from the same order.
The order has not been published. The Agencia Tributaria’s own information note on the Real Decreto said the public consultation on the draft was expected to open in April 2026, and it did: the proyecto de orden went to audiencia e información pública on 16 and 17 April, and that consultation closed on 3 June. As at 9 September 2026 the final text has still not appeared in the BOE.
The draft sets its own entry into force at 1 October 2026. If that survives into the published version, the large-business phase would fall on 1 October 2027 and everyone else, autónom@s included, on 1 October 2028. Those are draft dates rather than law, and this particular reglamento was already three and a half years late, so they are worth holding loosely.
There is a useful contrast here, because the two regimes get discussed as though they were one thing. Verifactu has firm dates in published law. Mandatory B2B e-invoicing has no date at all until that order appears. If something you have read gives you a single deadline covering both, it is wrong about at least one of them.
The floor, though, is fixed: the order cannot predate the regulation it is made under, so this cannot reach autónom@s before spring 2028 at the very earliest. If you have read that mandatory e-invoicing arrives in Spain in late 2026, it does not.
Three regimes, then, and they get conflated constantly:
| Regime | What it governs | Where it lives |
|---|---|---|
| Invoice timing | When you must issue | RD 1619/2012, Art. 11 |
| Verifactu | Integrity of the billing record | Ley 11/2021, RD 1007/2023 |
| Mandatory B2B e-invoicing | Format and transmission | RD 238/2026, Art. 8 bis |
You can be inside one and outside another. A reminder that treats them as a single thing will always sound more alarming than the position it describes.
What this means in practice
If you invoice businesses in Spain, you have until the 15th of the following month, and you have had since 2013. Verifactu did not shorten it. The e-invoicing mandate does not shorten it either.
What has genuinely changed is that the date on the invoice and the date it was actually created are now tied together, so the old habit of writing last month’s date on this month’s invoice no longer works. That is worth knowing. It is a narrower change than the reminders suggest.
FAQ
Do I have to invoice on the same day I do the work in Spain? Only where your customer is a private individual. Where the recipient is a business or professional acting as such, Article 11 of RD 1619/2012 gives you until before the 16th of the month following the month in which the VAT became due.
Did Verifactu change the invoice deadline? No. Article 11 was last amended in 2013. Verifactu governs the integrity and traceability of the billing record, not the schedule on which invoices may be issued.
Can I still date an invoice at the end of last month if I create it this month? Not under a Verifactu-certified system. The record carries the real generation timestamp, so issue date and record no longer diverge. This is the practical change Verifactu makes.
When does mandatory e-invoicing start for autónomos in Spain? No date is fixed yet, and as at September 2026 the ministerial order that starts the clock is still a draft. The clock runs from a ministerial order developing the AEAT public e-invoicing platform, and autónom@s fall twenty-four months behind that order. The order has not been published. A draft reported in professional commentary would put autónom@s at 1 October 2028, and the arithmetic floor is spring 2028 regardless.
Is a monthly invoice for a continuing service allowed? Recapitulative invoicing for periodic services is normal practice, but where the devengo falls in a continuing arrangement is a question for your gestor, and it determines which month’s deadline applies.
Sources
- Real Decreto 1619/2012, Reglamento de facturación, Artículo 11 (consolidated)
- Real Decreto 828/2013, de 25 de octubre – adds Art. 11.3, cash-basis scheme
- Real Decreto 238/2026, de 25 de marzo – mandatory B2B e-invoicing, Art. 8 bis
- Ley 18/2022, de 28 de septiembre, “Crea y Crece”
- Agencia Tributaria – nota informativa on RD 238/2026
