Spain Provides New Technical Detail on B2B E-Invoicing System

Spain’s Tax Agency has provided further details on the country’s future B2B e-invoicing system, clarifying how its public platform will operate alongside private providers and how invoices will be tracked beyond issuance and delivery.

During a technical webinar on 10 September, the Agencia Estatal de Administración Tributaria (AEAT) said the Ministerial Order needed to complete the regulatory framework was in the final stages of processing. Its publication is expected during October 2026, although the agency acknowledged that it may not meet the previously targeted date of 1 October.

This timing matters because the implementation deadlines are linked to the Order entering into force. Businesses with annual turnover above €8 million are expected to comply 12 months later, with other businesses following after 24 months. Publication after 1 October would therefore make the widely cited deadlines of 1 October 2027 and 1 October 2028 subject to confirmation.

Spain is explicitly developing a hybrid model that will combine private e-invoicing platforms with the AEAT-managed Public Electronic Invoicing Solution, known as the SPFE.

Under the current draft, invoices will not have to be exchanged directly through the public platform. However, when an invoice is exchanged outside the SPFE, a 'faithful copy' (copia fiel) must be submitted to the public system at the same time as it is issued.

The model will also track invoices beyond their initial delivery. It includes lifecycle statuses covering rejection, payment, collection and non-payment, with reporting obligations involving both invoice issuers and recipients.

Recipients will be required to communicate the full payment of an invoice, together with the relevant payment and due dates, or report that the invoice has been rejected. Invoices that are not rejected will be presumed accepted. Issuers will also participate in lifecycle reporting, including communicating collection and non-payment information where applicable.

The technical architecture is becoming clearer. The SPFE will use UBL 2.5, aligned with the EN 16931 semantic model, and will validate invoices against UBL, EN 16931 and additional AEAT-specific rules.

The specifications also provide for ebXML messaging and web services covering invoice submission, cancellation, consultation, download and lifecycle status changes.

Detailed technical documentation and a testing environment are expected to become available following publication of the final Ministerial Order.

Spain is also considering how its B2B e-invoicing regime could eventually be aligned more closely with its existing SII and VERI*FACTU systems. A recent Spanish Senate motion called for the three frameworks to be progressively integrated and aligned with the EU’s VAT in the Digital Age requirements. However, the motion is non-binding and does not itself change the implementation timetable.

Sources:

The E-Invoicing Hub

SPFE PDF

Thomson Reuters

Royal Decree

Webinar Materials

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