Published: 08 June 2026
Spain’s B2B e-invoicing framework is moving toward a phased implementation built around the Public Electronic Invoicing Solution, known as SPFE. According to AEAT’s seminar materials, the draft Ministerial Order is expected to enter into force on 1 October 2026, with obligations starting for large companies in 2027 and the remaining businesses in 2028.
The first AEAT document focuses on the draft Ministerial Order regulating the SPFE and explains the functional design of Spain’s upcoming B2B e-invoicing system. The system is presented as a mixed model, combining private platforms with a public solution managed by the Spanish Tax Agency. The SPFE will not only operate as a free invoicing tool for businesses and professionals, but also as a universal repository for faithful electronic copies of invoices, an interconnection mechanism between private platforms, and a system for managing invoice and payment statuses.
The scope described in the material refers to businesses and professionals subject to Spanish invoicing obligations, where the recipient is also a business or professional with a seat of economic activity, permanent establishment, domicile, or habitual residence in Spain. The materials also mention exceptions, including simplified invoices and excluded sectors, although the full details are not developed in the presentation.
A key element of the model is the “copia fiel”, or faithful electronic copy. Where an invoice is not issued or interconnected through the SPFE, a faithful copy must be submitted to the SPFE simultaneously with issuance. These copies must follow the semantic, syntactic and technical specifications defined for the public solution and will be marked as copies within the system.
The same document also provides a timeline. The Ministerial Order is expected to enter into force on 1 October 2026. Mandatory B2B e-invoicing will apply from 1 October 2027 for large companies with turnover above EUR 8 million, and from 1 October 2028 for the remaining businesses. Payment reporting will follow a phased approach, beginning with large companies in 2027, SME legal persons in 2028, and certain smaller taxpayers and individuals in 2029.
The second AEAT document addresses the technical aspects of the SPFE. It confirms that the public solution will work exclusively with UBL syntax and will rely on the EN 16931 semantic model. UBL will support invoices, faithful copies, payment confirmations, rejection messages and invoice status-related communications.
AEAT also explains that Spain will use UBL extensions to cover domestic invoicing requirements not fully addressed by the European semantic model alone. Validation will include UBL XSD syntax checks and EN 16931 Schematron-based semantic checks. However, AEAT notes that no online invoice validation service will be available in production, meaning senders and platforms will need to validate invoices before submission.
Before the test environment is deployed, AEAT plans to publish technical documentation through its Developers Portal, including service catalogues, WSDLs, XSD schemas, Schematron validation documents, error lists and sample XML messages.
(find other details here Spain e-Invoicing)
