Editorial: e-invoicing can help firms get paid, if they prepare in time

This is an editorial by the AGENTE LEX newsroom. It expresses the portal's opinion.

Every time a new technology obligation arrives, the sector's reaction is usually the same: another burden, another program, another cost. With mandatory e-invoicing between businesspeople and professionals it is understandable. But it would be a mistake to stop at that reading.

Royal Decree 238/2026, whose timetable started with the entry into force of Order HAC/1028/2026 on 6 October, does not merely swap paper or PDF for a structured file. It introduces something of great interest to those who live by collecting fees: information on payment.

What the rule says

Article 10 of the royal decree obliges the invoice recipient to inform the issuer of two things:

• The commercial acceptance or rejection of the invoice, with its date.
• The full effective payment, with its date.

The period is four calendar days, excluding Saturdays, Sundays and national holidays. Article 12 also obliges full payment to be reported to the Tax Agency's public solution, and establishes that failure to reject implies acceptance.

According to the Tax Agency, the obligation to issue and receive e-invoices will arrive on 6 October 2027 for those above 8 million euros in turnover and on 6 October 2028 for the rest. Individuals will have one more year to report invoice statuses.

Why it is good news for firms

Every firm knows the situation: an invoice sent to a corporate client that nobody rejects, nobody disputes and nobody pays. Weeks later, the answer is that "we have no record" or that "it is in the approval circuit".

With the new system, the invoice leaves a trail. The client will have to accept or reject it, and the firm will know when they did. Silence equals acceptance. And payment will be recorded with its date.

It will not solve all delays, but it will give the firm objective information to claim on solid grounds and to know how each client pays. And that information will have a certain date, because it will be recorded in the system itself and will not depend on emails or calls.

What we ask

Of firms, not to wait until 2028. Choosing software compatible with the new invoice, tidying series and client data and trying the public solution when available takes time. Doing it calmly is cheaper than doing it in a hurry.

Of the bar associations, to include e-invoicing in their training and offer practical guidance to those who practise alone or in small firms. The public solution is free, according to the order, and is designed for SMEs and professionals. Making sure they know it is the best way to stop the obligation turning into an unnecessary cost.

Of the Administration, to do its part: the order requires the public solution to be available at least two months before its first effective application. That margin is short for anyone who has to change software, and it is wise for the tool to be operational as soon as possible.

An opportunity to put the firm in order

E-invoicing forces a review of processes that some firms may have left informal: when to invoice, with what data, how collection is followed up. It is a good time to do it, and to link it with a clear engagement letter from the start, as we argue in the editorial "The engagement letter should be the rule".

The practical details of the timetable and the public solution are in our guide to mandatory e-invoicing for lawyers. More editorials in Opinion.