Spain Publishes Ministerial Order Starting the B2B E-Invoicing Countdown

Spain has published Order HAC/1028/2026 in the Official State Gazette (BOE) on October 5, 2026. The order took effect on October 6, 2026, and governs the technical and functional aspects of the public e-invoicing solution managed by the Spanish Tax Agency (AEAT). Its entry into force starts the clock on every compliance deadline set by Royal Decree 238/2026 of March 25, 2026, which develops the B2B e-invoicing obligation introduced by the Crea y Crece Law (Law 18/2022).

Implementation Timeline

• October 6, 2027 – businesses and professionals whose volume of operations exceeded €8 million in the preceding calendar year
• October 6, 2028 – all remaining businesses and professionals
• October 6, 2029 – mandatory payment status reporting for self-employed individuals and income attribution entities with a volume of operations with turnover of up to €8 million

First-phase suppliers must send a PDF alongside the e-invoice unless the customer expressly agrees to receive only the original e-invoice. The AEAT public solution must be available no later than August 6, 2027, two months before the first compliance date.

Scope of Obligation

The obligation covers B2B invoicing where the recipient has its business establishment, a permanent establishment, or its domicile or habitual residence in Spain. Simplified invoices are excluded, except qualified simplified invoices under Article 7.2.

Technical Requirements

Invoices can be exchanged through private e-invoicing platforms, the free public solution operated by AEAT, or a combination of both. Private providers must interconnect with each other at their customers’ request, and the public solution can serve as an alternative means of interconnection. The order sets out:

• The data model based on the European semantic standard EN 16931, using UBL syntax
• The obligation to send a faithful copy in UBL format of invoices issued outside the public solution, at the time of issuance
• Unique invoice coding rules and authentication methods
• Messages on invoice status and payment, including rejection, full payment, and non-payment
• Procedures for submission, validation, error correction, and invoice retrieval

Additional technical specifications, conditions, and volume parameters will be published on the AEAT electronic office. The reporting framework is designed to give the government reliable data on late payments in commercial transactions.

There’s more you should know about e-invoicing in Spain – learn more about the new and upcoming regulations.