Spain's Ministry of Finance has published the Ministerial Order HAC/1028/2026, setting a phased timetable for the B2B e-invoicing mandate that begins on 6 October 2027.
Spain’s Ministry of Finance (MoF) has published the Order HAC/1028/2026 in the official gazette BOE on 5 October 2026, fixing the dates from which businesses must comply with the B2B e-invoicing mandate. The order enters into force the day after publication. The draft had expected publication on 1 October, but the final text appeared a few days later.
Phased timetable
- 6 October 2027: Businesses with turnover above EUR 8 million must issue e-invoices, report a faithful copy and report the corresponding invoice statuses. For the first year, each e-invoice must also be accompanied by a PDF.
- 6 October 2028: The same obligations apply to businesses with turnover below EUR 8 million, except self-employed taxpayers.
- 6 October 2029: Self-employed taxpayers with turnover below EUR 8 million must report the corresponding invoice statuses.
Legal framework and scope
The order regulates the technical and functional specifications of the Public Electronic Invoicing Solution (solución pública de facturación electrónica), which is developed, hosted and managed by the Spanish Tax Agency (AEAT – Agencia Estatal de Administración Tributaria). It completes the framework set under Article 2 bis of Law 56/2007, introduced by Law 18/2022 “Crea y Crece” and updated by Law 7/2024, and under Royal Decree 238/2026.
The rules apply to all businesses and self-employed professionals (empresarios y profesionales) issuing invoices where the recipient has their economic activity, permanent establishment or tax residence in Spain.
Public solution and private platforms
The Spanish framework combines private exchange platforms with the Public Solution, which is free of charge. It serves as a basic exchange tool for small businesses and freelancers and as a universal repository for all B2B invoices.
Private platforms must automate access to retrieve incoming invoices for their clients to meet statutory storage requirements.
Technical requirements and faithful copies
Invoices issued through private platforms must be sent at the same time to the Public Solution as an exact faithful copy (copia fiel). All invoices and faithful copies must follow the European EN 16931 semantic data model in UBL (Universal Business Language) syntax, with faithful copies flagged as CopyIndicator = True.
Neither may contain embedded attachments, although electronic signatures can accompany interconnected invoices. Each invoice receives a unique code formed from the issuer’s Tax ID (NIF), series, invoice number and issue date.
Invoice status reporting
Recipients must report invoice status events electronically, including the full effective payment date, the payment due date or a rejection. Issuers may voluntarily report payment collection, non-payment or discrepancies. Without an explicit rejection or a rectifying invoice, an invoice is legally presumed accepted.
Access and outages
The Public Solution can be accessed through Web Services (machine-to-machine) and interactive Web Forms on the AEAT Electronic Headquarters, using valid electronic certificates or the Cl@ve system for web forms. Legal and tax representation is supported.
If an AEAT public service outage lasts more than 24 hours, businesses receive a grace period of four business days after resolution to submit pending invoices or faithful copies. The AEAT must have the Public Solution online at least two months before the mandatory application date.
With the technical specifications now set out in the annexes, businesses and private platform providers have a defined timeline to prepare their systems.
