Published: 1 May 2026
Following the adoption of the Royal Decree establishing the legal framework for B2B e-invoicing in Spain, the publication of the draft Ministerial Order marks the next step, focusing on the technical and operational design of the system.
The draft, released by the Ministry of Finance, has entered a public consultation phase and provides the first detailed view of how the system is expected to operate in practice.
The proposed regulation outlines the functioning of the public platform managed by the Spanish Tax Agency (AEAT), including how businesses may issue and receive electronic invoices, as well as how invoice data must be transmitted when private service providers are used. It also introduces mandatory invoice status reporting, covering acceptance, rejection, and payment, and establishes interoperability requirements between public and private platforms.
In addition, the draft addresses user identification, authentication, and representation rules, and confirms the use of structured formats aligned with European standards.
While the draft refers to a potential implementation start from October 1, 2026, this date remains indicative and non-binding. The consultation is open until May 8, 2026, after which the text may be revised before formal adoption.
The phased enforcement timeline will only be triggered once the Ministerial Order is officially published, with large companies expected to comply first, followed by smaller businesses after a transition period.
