E-invoicing in Spain: Complete Guide

Latest Update (October 2026): Order HAC/1028/2026 published

On 5 October 2026, Order HAC/1028/2026 of 2 October was published in the Spanish Official State Gazette (BOE). The Order sets out the technical and functional elements of the Public E-Invoicing Solution (SPFE). It entered into force on 6 October 2026, the date from which the effective application periods under Law 18/2022 and Royal Decree 238/2026 are counted.

According to the implementation calendar published by the Spanish Tax Agency (AEAT), the obligation to issue and receive e-invoices will become mandatory:

• from 6 October 2027 for businesses and professionals whose turnover exceeded €8 million in the preceding calendar year;
• from 6 October 2028 for all other businesses and professionals.

The AEAT must make the SPFE available at least two months before the first effective application date. Technical specifications, conditions and volume limits for the web services will be published on the AEAT's e-office (Sede electrónica).

Among the points clarified in the final text are the minimum content of e-invoices and faithful copies, with faithful copies flagged through a dedicated copy indicator. The Order also allows an exceptional period of four business days to submit invoices and communications where the SPFE suffers technical incidents lasting more than 24 hours. Finally, the payment communication obligation is deemed fulfilled where the invoice itself already shows a payment date on or before its issue date.

E-invoicing Mandate in Spain

Spain's mandatory B2B e-invoicing framework is now fully in motion. With Royal Decree 238/2026 published in March 2026 and Ministerial Order HAC/1028/2026 published on 5 October 2026, the regulatory framework is complete and the implementation dates are now confirmed. This article brings together the key rules, timelines and technical details from official sources.

The obligation applies to all businesses and professionals (empresarios y profesionales) subject to Spanish invoicing regulations under Royal Decree 1619/2012, for transactions where the recipient is a business established in Spain, and where the supply is directed to that establishment.

This covers domestic B2B transactions between Spanish-established entities. B2C transactions and simplified invoices remain outside the mandate. The position of non-established businesses with a Spanish VAT registration has not been definitively clarified in the published texts, and businesses in this situation should monitor further guidance.

Exclusions include transactions that may use simplified invoices (as per Article 4 of RD 238/2026), sectors specifically excluded by the Second Additional Provision, and certain particularities under the seventh paragraph of the twenty-first Additional Provision of Law 56/2007.

Implementation Timeline

The go-live dates are triggered by the entry into force of the Ministerial Order. Order HAC/1028/2026 entered into force on 6 October 2026, and the AEAT has confirmed the following schedule:

During the first 12 months of mandatory compliance, large businesses must accompany each e-invoice they issue with a PDF document to ensure readability for businesses not yet within the mandate.

The Spanish E-invoicing System: Architecture

Spain's system combines two complementary channels through which businesses can issue and receive e-invoices.

Private platforms

Businesses may use interoperable private invoicing platforms (plataformas privadas de intercambio).

These are not required to use the SPFE directly to issue invoices, but they must simultaneously send a faithful electronic copy (copia fiel) of each invoice in UBL syntax to the SPFE at the moment of issuance. Where the invoice is issued by the recipient (self-billing) or by a third party, the faithful copy must be sent by the platform used by that recipient or third party. If a faithful copy is rejected by the SPFE, the original invoice remains valid, but the copy must be corrected and resubmitted.

Private platforms are configured as routing hubs for invoice traffic, and they are required to recover electronically exchanged invoices from the SPFE automatically and make them immediately available to their clients.

Public E-Invoicing Solution (SPFE)

The Public E-Invoicing Solution (Solución Pública de Facturación Electrónica, SPFE) is a free solution managed by the AEAT, available to all businesses and professionals. It serves two functions simultaneously: it is the default tool for businesses that do not use a private platform, and it is the universal repository for faithful copies of all e-invoices issued through private platforms. Its key features are:

• Invoice issuance via a web form, on an individual, per-invoice basis.
• Interconnection with private platforms, and submission of faithful copies, via web services.
• Management of payment status communications.
• Access, consultation and retrieval of invoices, faithful copies and their statuses.

Technical Format Requirements

The Spanish e-invoicing system adopts UBL (Universal Business Language) as the reference syntax, chosen because it complies with the European standard EN 16931 and is the most widely used of the two syntaxes permitted under EU Directive 2014/55/EU on e-invoicing in public procurement. Both invoice issuance via the SPFE and interconnection through private platforms must follow the EN 16931 semantic data model under UBL syntax.

E-invoices and faithful copies are subject to syntax and semantic validation against the EN 16931 (2026) data model and the technical specifications published on the AEAT's e-office. After validation, the AEAT returns a response listing the accepted submissions and, where applicable, the rejected ones with the reason for rejection.

Each invoice must include a unique code (as required by Article 7.5 of RD 238/2026), generated by concatenating the issuer's NIF (tax identification number), the invoice series and number, and the issue date. This ensures full traceability and prevents duplication.

Invoices may be sent with an electronic signature via interconnection, but neither invoices nor faithful copies may incorporate embedded or integrated files of any kind.

Payment Status Reporting: A Key Additional Obligation

Beyond e-invoice exchange, one of the most distinctive features of the Spanish system is the mandatory reporting of invoice status throughout its lifecycle. This goes further than simple invoice exchange and is designed to monitor payment terms and combat late payment in the private sector.

Recipients (buyers)

Recipients must report to the SPFE:

• Mandatory: rejection of the invoice, where applicable (in the absence of a rejection or a subsequent corrective invoice, the invoice is presumed accepted); date of full effective payment; payment due date.
• Optional: date of receipt of the goods or performance of the services, or date of receipt of the invoice, where relevant under the late payment rules.

Where the invoice itself, or its faithful copy, already includes a payment date on or before its issue date, and that date matches the transaction or chargeability date, the recipient's payment reporting obligation is deemed fulfilled, unless the recipient expressly reports the payment status. A rejection may only be based on one of two grounds: commercial rejection, or the transaction being a private purchase or unrelated to the business activity.

Issuers (suppliers)

Issuers may report to the SPFE:

• Effective collection (cobro efectivo) of the invoice.
• Non-payment (impago).
• Discrepancies with dates reported by the recipient.

Communications are made either via a web form (identifying the invoice individually) or via web services (identifying the invoice by its unique code), and each admitted communication receives an acknowledgement of receipt with a Secure Verification Code (CSV). Erroneous communications can be cancelled, with full traceability maintained. Where the SPFE is unavailable for more than 24 hours for technical reasons attributable to it, invoices, faithful copies and status communications may be submitted within the four business days following the resolution of the incident.

Access and Authentication

Access to the SPFE requires authentication via an electronic certificate. Where the web forms are used (invoice generation, status communication or consultation), the Cl@ve system may also be used.

Businesses may access the SPFE directly or through an authorised representative or social collaborator (colaborador social). However, where a third party uses the invoice generation form or the status communication form on the business's behalf, it must be an attorney registered in the AEAT's power of attorney registry (Registro de apoderamientos). The same requirement applies to accessing the invoice retrieval and consultation services, whether via web service or web form.

Current E-invoicing Rules in Spain

Until the B2B mandate takes effect, e-invoicing in Spain is mandatory only for transactions with public administrations (B2G), a requirement in place since 2015. In B2B transactions, e-invoicing remains voluntary and requires the agreement of both the supplier and the customer.

How can Marosa by Wolters Kluwer help you?

Our proprietary software, VATify by Wolters Kluwer, incorporates an e-invoicing module allowing you to issue and receive invoices across Europe and beyond using a single standard file.

Check out the countries where we’re authorised to issue e-invoices here.

Contact our team to see a demo of how VATify can be your single platform for all European e-invoicing and VAT reporting obligations.

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