Published: 08 October 2026
Spain has officially confirmed the implementation timeline for its mandatory B2B e-invoicing system following the publication of Ministerial Order HAC/1028/2026 in the Official State Gazette (BOE) on October 5, 2026. The order enters into force on October 6, 2026, triggering the countdown periods established under Spain’s B2B e-invoicing framework.
The mandate will be introduced gradually:
- October 6, 2027: Businesses and professionals with annual turnover above EUR 8 million must comply with mandatory B2B e-invoicing requirements.
- October 6, 2028: The obligation extends to the remaining businesses and professionals within scope.
- October 6, 2029: Mandatory invoice-status reporting will also apply to the relevant taxpayers subject to the transitional rules for smaller businesses and self-employed professionals.
Spain will operate a hybrid e-invoicing model, combining private e-invoicing platforms with the public solution managed by the Spanish Tax Agency (AEAT). Businesses using private platforms instead of the public solution for invoice issuance or interconnection must simultaneously transmit a faithful electronic copy (copia fiel) of each invoice to the public system in UBL format.
Technical Requirements
Electronic invoices processed through the public solution must follow the EN 16931 semantic data model and UBL syntax. Each invoice will also be identified through a unique code (Código Único) generated from the issuer’s NIF, invoice series and number, and issue date.
Invoices and faithful copies submitted to the public system cannot contain embedded files or attachments. However, invoices exchanged through the public solution may be transmitted together with an electronic signature.
Access to the AEAT public solution will rely on electronic authentication mechanisms, including certificates accepted by the AEAT and, for certain web-form services, the Cl@ve identification system. Third parties acting on behalf of businesses must have the appropriate authorization or representation registered with the Spanish Tax Agency.
Invoice Status and Payment Reporting
The framework also introduces electronic reporting of invoice and payment statuses. The invoice recipient must report information such as invoice rejection and the effective full payment date, while the issuer may voluntarily communicate information concerning collection or non-payment. These communications will also use UBL-based messaging.
The public solution will support web services and machine-to-machine communication for invoice exchange, faithful-copy submission, invoice retrieval and status reporting. If the AEAT public system is unavailable for more than 24 hours due to a technical incident, affected submissions may be completed within the following four business days after the service is restored.
The AEAT public e-invoicing solution must be available at least two months before the first effective application date, allowing businesses and service providers time to prepare ahead of the October 2027 rollout.
(find other details here Spain e-Invoicing)
