B2B e-invoicing is not a PDF in an email

If you email a PDF and call it an “electronic invoice”, Crea y Crece is not talking about that. Law 18/2022 and Royal Decree 238/2026 of 25 March (BOE 31 March 2026) regulate mandatory e-invoicing between businesses and professionals: a structured computer message, not a scan and not an exported Word file.

Searches for “factura electrónica obligatoria”, “ley crea y crece” and “when does B2B e-invoicing start” mix three clocks. One: the decree enters into force twenty days after publication. Two: effective application is deferred from a Hacienda ministerial order (final provision three.1). Three: Verifactu (the billing system you issue with) is a different rule, with 2027 deadlines. A pack that welds all three plus an OCR reader is a sales pitch, not the BOE.

This page does not replace the AEAT site or your adviser. It exists so you do not sign a “2026 e-invoice kit” that mixes issuing, extracting and destroying paper.

What the duty is, in shop-floor language

Many SMEs already “invoice electronically” by attaching a PDF to an email. The customer prints it or files it. That can be a valid PDF invoice; it is not Crea y Crece B2B e-invoicing. The rule wants a message another machine can read without retyping: issuer, recipient, bases, VAT, due date, identifiers.

Royal Decree 238/2026 sets the technical and information requirements of that system between businesses and professionals, and the requirements for exchange platforms. The AEAT will develop a free application or form that, under conditions, will let you issue e-invoices, generate status information — including full actual payment — and make it available to counterparties and the administration through the public e-invoicing solution.

That public solution must be available at least two months before the decree’s first effective application (final provision four). Until Hacienda publishes the order that starts the clock, there is no “already mandatory for my shop” date. Anyone selling “everyone in 2026” is reading half the BOE.

When it actually applies

The decree enters into force twenty days after BOE publication. That is not the day you must send UBL to every customer. Effective application is counted from the entry into force of the ministerial order in final provision three.1:

• Twelve months later, if last calendar year’s volume of operations — computed as VAT Act article 121 — exceeded €8 million.
• Twenty-four months later, for every other business and professional.

Without that order, the 12/24-month calendar has not started. Keep the AEAT note of 31 March 2026 and ask your adviser when the order lands. Do not sign a “2026 deadline” that does not cite that provision.

When it starts, larger firms go a year earlier. A twelve-person SME is not in the same tranche as a group that billed €20 million. A salesperson who applies the twelve-month tranche to a self-employed person is inventing the annex.

Which format counts (EN16931)

The e-invoice is a structured message that matches the EN16931 semantic model, in one of these syntaxes: CII; UBL (with the adaptations needed between businesses and professionals); an EDIFACT invoice message; a Facturae message. On private platforms, Peppol BIS also counts if it uses UBL syntax and conforms to EN16931.

Private exchange platforms must be able to transform the message among all admitted formats while preserving authenticity of origin and integrity of content. That is interoperability, not “our proprietary XML”. If your vendor speaks one dialect and the customer another, the transformer is the platform operator — or the public solution — not an intern copying fields.

A Verifactu billing record is not that invoice. Generating the SIF Alta does not turn a PDF into Crea y Crece. The reverse is also false: a well-formed UBL does not make Word a legal SIF if you still issue from a template.

What B2B e-invoicing is not

• Not Verifactu / VERI*FACTU. The SIF rules the programme you issue with; Crea y Crece rules the B2B exchange format.
• Not an invoice OCR reader. OCR reads what suppliers send you (inbound). E-invoicing is the structured exchange when you issue and receive between firms.
• Not certified digitisation (Order EHA/962/2007). A signed image of paper is not an EN16931 message.
• Not “mandatory tomorrow for everyone”. The 12/24-month clock does not run until Hacienda’s order.
• Not whichever Kit Digital voucher name you like. The official catalogue has an e-invoicing line; this site does not list that slug. We do not recite it to sell OCR.

Kit Digital and this studio: no invented catalogue shortcut

Red.es publishes a billing / e-invoice category. These pages have no “factura-electronica” slug: we offer issue or capture flows inside process management when they fit, and Kit Consulting advisory when the map still needs writing. Adhesion is in progress. We do not claim Adherido.

AEAT’s SIF FAQ (updated 21 July 2026) says the free VERI*FACTU app might later help with B2B e-invoice issuance. “Might” is not “already issues Crea y Crece”. Do not sell the FAQ as a finished product.

If this week’s pain is retyping supplier invoices, that does not wait for the ministerial order. That is capture. We have an invoice OCR reader to extract fields and leave a human the ones that do not add up. It is not B2B e-invoicing. We do not brand it as Crea y Crece.

What to do this week

List what you issue with today (programme, template, accountant) and what you receive (PDF, paper, EDI). Split three drawers: SIF/Verifactu issuance; Crea y Crece B2B exchange; supplier capture. Each drawer has an owner and a different date.

Ask your software: does it issue EN16931 (CII, UBL, EDIFACT or Facturae)? Does it talk to an exchange platform or the public solution? What happens when the customer wants another format? If the answer is “we still send the PDF”, you are not in Crea y Crece. You are in email.

Do not destroy paper because you ran a scan. That is another order. Do not wait until 2027 to stop retyping supplier invoices: that is the reader, not the decree.

Frequently asked questions

When is B2B e-invoicing mandatory?

RD 238/2026 enters into force twenty days after publication. Effective application is 12 or 24 months from Hacienda’s ministerial order (final provision three.1), depending on whether last year’s operations exceeded €8 million. Without that order there is no “already” day.

Is it the same as Verifactu?

No. Verifactu/SIF is the regime of the issuing programme (2027 deadlines, common-regime territory). Crea y Crece is the structured format between firms. An Alta record is not the e-invoice.

Will the AEAT provide a free solution?

Yes: a free application or form and the public e-invoicing solution, which must be ready at least two months before first effective application. Conditions sit on the AEAT site.

Does invoice OCR meet Crea y Crece?

Not if it only extracts fields from inbound invoices. That is capture. An invoice OCR reader does not emit an EN16931 message or replace an exchange platform.

Next: what Verifactu is, Kit Digital and the SIF, and the invoice OCR reader. Tell us whether the problem is issuing, exchanging or retyping.