On 17 April 2026, the Spanish Tax Authority (AEAT) published for public consultation the draft Ministerial Order regulating the AEAT-operated public e-invoicing solution. The consultation period closes on 8 May 2026. The Order, once finalised and published in the Official State Gazette (BOE), is planned to enter into force on 1 October 2026, at which point the compliance countdowns under Royal Decree 238/2026 and Ley 18/2022 will begin.
What the draft order covers
The Order implements the technical and functional specifications for the public solution. The key provisions are:
-
Invoice format: All invoices issued or exchanged through the public solution must use EN 16931-compliant UBL syntax. UBL is also the mandatory format for faithful copies submitted by businesses using private platforms.
-
Exchange of invoices: Invoices may be exchanged either through a public platform operated by the tax authorities or through accredited private platforms. In the latter case, the private platform must transmit a copia fiel (faithful copy) of the invoice to the tax authority in UBL format.
-
Unique invoice code: Each invoice must carry a unique identifier based on the concatenation of the issuer’s tax identification number (NIF), invoice number and series, and issue date.
-
Payment status communications: Invoice recipients must report commercial acceptance or rejection and full effective payment — including payment date and due date — to the public solution within 4 calendar days. All status messages use UBL syntax, as specified in Annex II of the Order. Invoice issuers may voluntarily report collection or non-payment.
-
Invoice retrieval: Private platforms using the public solution as an interconnection hub must automate retrieval of received invoices and make them immediately available to recipient clients.
-
Authentication: Access to the public solution requires qualified electronic certificates. The Cl@ve system is also accepted for web form submissions.
-
Public solution availability: AEAT must make the public solution operational at least two months before the first compliance deadline.
What remains outstanding
The detailed technical specifications, schemas, and API contracts for the public solution interface — which are essential for platform integration — are not included in the Order. They will be published separately by AEAT on its Sede Electrónica at a future date.
Key compliance deadlines
1 October 2026 – Expected entry into force of Ministerial Order (planned). This is the trigger date for all compliance countdowns;
Est. August 2027 – the public solution will be operational, at least two months before the first compliance deadline;
1 October 2027 – Private platforms to meet the obligations for faithful copy, interoperability and technical requirements;
1 October 2027 – Large businesses (turnover >€8M in prior year) to comply with the e-invoicing and invoice status requirements. During the following 12 months, these businesses must also provide a PDF copy alongside each e-invoice (unless the recipient expressly waives this);
1 October 2028 – All remaining businesses and professionals to comply with e-invoicing and invoice status requirements;
1 October 2029 – Status reporting deferred for sole traders / IRPF attribution entities (≤€8M).
Businesses and service providers have a direct interest in responding to this consultation as stakeholder input at this stage can influence how the final requirements are defined. Responding also provides an opportunity to raise practical considerations around implementation timelines, payment status reporting workflows, and message format requirements before the Order is finalised. Submissions must be made before 8 May 2026.
Sovos is monitoring this consultation and will provide a further update once the final Order is published. This page will be updated as developments occur.
