Published: 18 September 2026
Spain’s Tax Agency (AEAT) provided further regulatory and technical details on the country’s upcoming mandatory B2B e-invoicing system during its Solución Pública de Facturación Electrónica (SPFE) webinar held on September 10, 2026.
The session focused on the revised draft Ministerial Order governing the public e-invoicing solution and the technical services that will support Spain’s future B2B e-invoicing framework.
Implementation timeline
The final Ministerial Order is currently targeted for publication and entry into force in October 2026. Its entry into force is particularly important because it starts the countdown for the mandatory rollout.
Under Royal Decree 238/2026, the obligation will apply:
- 12 months after the Order enters into force for businesses and professionals whose annual volume of operations exceeds EUR 8 million.
- 24 months after entry into force for all remaining businesses and professionals.
- Certain individuals and entities under the income-attribution regime will receive an additional 12 months for mandatory invoice-status reporting.
If the Ministerial Order enters into force on October 1, 2026 as currently envisaged, the first two phases would therefore begin on October 1, 2027 and October 1, 2028, respectively.
Technical framework of the SPFE
AEAT also provided further information on the technical architecture of the public solution. The SPFE is expected to use UBL 2.5 aligned with the EN 16931 semantic model, while validation will cover structural, EN 16931 and Spain-specific business rules.
The public system will support services including:
- Invoice submission and retrieval
- Invoice cancellation
- Invoice searches and consultation
- Communication of invoice lifecycle events
- Payment-status reporting
Spain will operate a hybrid model, allowing businesses to use either private e-invoicing platforms, the public SPFE solution or a combination of both. Private platforms that do not issue invoices through the SPFE will nevertheless be required to send a faithful electronic copy of the invoice to the public system.
What happens next?
AEAT is expected to release the final technical documentation and a dedicated testing environment following publication of the Ministerial Order. Until the Order is formally published, the currently anticipated 2027 and 2028 dates should therefore be treated as expected rather than legally fixed implementation dates.
(find other details here Spain e-Invoicing)
