E-Invoicing Compliance in France and Spain (2026): What’s Live, What’s Delayed, and What Comes Next

E-invoicing compliance in France and Spain is live in some places, imminent in others, and delayed in Spain’s biggest system. France has required electronic invoicing for public-sector suppliers since January 1, 2020 (economie.gouv.fr). France’s B2B mandate takes effect September 1, 2026 (economie.gouv.fr). Spain’s SII reporting system has applied to large taxpayers since July 1, 2017 (Agencia Tributaria). Royal Decree-Law 15/2025 postponed Spain’s VeriFactu mandate a second time, to January 1, 2027 (BOE, Spanish primary source; KPMG, English summary).

If your public sector procurement platform operates in both markets, two deadlines define AP risk: France’s September 1, 2026 date, and Spain’s delayed VeriFactu date. This guide covers what’s live, what’s delayed, and what your AP stack needs to handle both mandates. It keeps sourced facts and editorial analysis clearly separate throughout.

Mandate Status at a Glance

What’s Actually Live, Imminent, or Delayed

France’s B2G mandate is live. Public-sector suppliers have had to invoice electronically since January 1, 2020 (economie.gouv.fr). French public administrations have received invoices through Chorus Pro, France’s e-invoicing portal, since January 1, 2017. That part isn’t changing.

France’s B2B e-invoicing mandate for 2026 is imminent. Starting September 1, 2026 (economie.gouv.fr), every VAT-registered business in France must be able to receive e-invoices. Large and mid-sized companies must also issue them and file e-reporting data, in Factur-X, UBL 2.1, or CII format. Small and micro-enterprises get an extra year, until September 1, 2027.

Spain’s SII e-invoicing system is live. Spain’s e-invoicing landscape has three distinct regimes: SII (VAT reporting), VeriFactu (software integrity), and Crea y Crece (B2B invoice exchange). Run by AEAT, SII has covered large taxpayers since July 1, 2017 (Agencia Tributaria). Businesses above €6,010,121.04 in turnover, roughly €6 million, plus REDEME-scheme businesses and VAT groups, must file within four calendar days.

Spain’s e-invoicing requirement for 2026 is delayed twice over. Royal Decree 254/2025 first pushed VeriFactu’s original mid-2025 timeline to January and July 2026 (BOE). Royal Decree-Law 15/2025 then moved those dates again, to January 1, 2027 for corporate taxpayers and July 1, 2027 for everyone else (BOE).

Spain’s B2B e-invoice exchange mandate is separately delayed. Royal Decree 238/2026, in force since April 20, 2026 (BOE), implements the Crea y Crece Law (Law 18/2022) but defers compliance until a Ministerial Order takes effect. That order remains in draft. Its own text sets an October 1, 2026 effective date (Ministry of Finance draft). From that date, the Royal Decree gives businesses above €8 million turnover 12 months to comply, and everyone else 24 months (BOE).

What “Compliant” Actually Means for Your AP Stack

AP stack e-invoicing compliance in France and Spain rests on four requirements: invoice format, transmission channel, mandatory data fields, and archiving duration. EN 16931 sets the underlying e-invoice format requirements across Europe that Factur-X and Facturae both follow.

Full penalty detail, including e-reporting and software-vendor fines, is broken down in the next section.

What Happens If You Are Not Compliant

Non-compliance carries a direct financial cost in both countries, though the two regimes work differently.

France’s Law No. 2026-103, Article 123, sets the legal basis (Service Public). A first offense is forgiven if corrected on its own, or within 30 days of a tax administration request. “First” means none of the same kind in the current year or the prior three. Spain’s figures trace to Article 201 bis of the Ley General Tributaria, added by Ley 11/2021 (BOE).

What Changed in 2026

France tightened penalties and locked in the timeline. Law No. 2026-103 took effect February 19, 2026, raising the per-invoice fine and formalizing the accredited-platform framework (Service Public). The government also announced a tolerance approach for businesses facing genuine trouble at launch, without moving the September 1 date itself (economie.gouv.fr press release).

Spain delayed VeriFactu again. The BOE published Royal Decree-Law 15/2025 on December 3, 2025, the second VeriFactu postponement in eight months.

The Gap Most AP Stacks Have Right Now

Legacy ERP AP modules built for PDF invoices, EDI, or manual entry typically can’t generate Factur-X’s embedded XML. They also can’t meet VeriFactu’s integrity requirements without added software. Three gaps recur most often. Format conversion. Transmission routing. Archiving in the wrong place.

JAGGAER Global eInvoicing Compliance sits over an existing ERP and handles format conversion, platform routing, and compliant archiving without a system replacement.

Frequently Asked Questions

Next Steps

E-invoicing compliance in France and Spain now spans three deadlines, not two. France’s B2B deadline arrives September 1, 2026 (economie.gouv.fr). Spain’s VeriFactu deadline has moved twice, and Crea y Crece runs on its own, later timeline. An AP stack that handles all three in one workflow avoids three separate projects.

JAGGAER Global eInvoicing Compliance plugs into an existing JAGGAER source-to-pay platform or current ERP, handling format conversion, transmission, and archiving in one place.

This post is for informational purposes only and does not constitute legal or tax advice. Verify current requirements with DGFiP, AEAT, or a qualified local advisor before acting.