Spain’s B2B E-Invoicing Countdown Begins: First Deadline 6 October 2027

Spain has published Order HAC/1028/2026, establishing the technical and operational rules for the public e-invoicing solution managed by its tax authority, AEAT.

Published on 5 October 2026, the Order takes effect the following day, 6 October 2026, starting the implementation countdown under Royal Decree 238/2026. Mandatory B2B e-invoicing will apply from:

• 6 October 2027: Businesses and professionals whose turnover, calculated under Spain’s VAT rules, exceeded €8 million in the previous calendar year.
• 6 October 2028: Remaining businesses and professionals within scope.

Businesses and professionals within scope must issue and receive B2B e-invoices through private platforms, AEAT’s public solution, or both. Those issuing invoices outside the public solution must simultaneously submit a faithful electronic copy in UBL format, including the required invoice information.

Invoices issued or exchanged through the public solution must follow the European EN 16931 semantic standard using UBL syntax. Invoice copies submitted to the solution must also use UBL.

The Order also defines how invoice status and payment information will be communicated, including full-payment dates and payment due dates, alongside messages concerning rejection, collection and non-payment. It sets procedures for submission, validation, error correction and invoice retrieval.

For finance teams, the publication confirms the implementation timetable and the requirements for connecting invoicing and payment processes with AEAT’s public solution.

Read the Ministerial Order in the BOE.

Royal Decree

This content is intended to share insights and practical considerations based on industry experience. It does not constitute legal, regulatory, or financial advice. Regulatory requirements vary by jurisdiction and circumstance, so any compliance-related matters should be reviewed and validated with your own professional advisors.