Spain’s mandatory business-to-business (B2B) e-invoicing framework is now complete. On 5 October 2026, the Boletín Oficial del Estado (BOE) published the Ministerial Order that sets out how the Spanish Tax Agency’s free public e-invoicing solution works. The Order takes effect the following day, 6 October 2026, which starts the clock on every deadline under the Crea y Crece Law and Royal Decree 238/2026. For businesses established in Spain, the planning dates are no longer estimates.
When the obligation starts
Spain is introducing the mandate in waves, and the start date depends on the size of business.
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6 October 2027 – Businesses with a turnover above €8 million in 2026
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6 October 2028 – All other businesses and professionals
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6 October 2029 – Mandatory payment status reporting for small self-employed individuals and income attribution entities
Large businesses in phase one also get a 12-month transition. During that period, they must send a PDF copy alongside each e-invoice, unless the customer agrees to receive the e-invoice only.
What changes in practice
From go-live date, invoices sent to other businesses in Spain must be structured e-invoices. They can be exchanged through a private e-invoicing platform, through the Tax Agency’s free public solution, or through a mix of both.
The mandate also goes beyond the invoice itself. Buyers must report when they reject an invoice and when they’ve paid it in full, within short, fixed deadlines. Suppliers can choose to report when they receive payment or when a payment is overdue. This reporting is central to the law’s purpose, which is to give the government reliable data on late payments.
The Order sets the data model and format for invoices exchanged through the platform operated by the Spanish Tax Agency, based on the European standard EN 16931 and the Universal Business Language (UBL) syntax. It also sets the authentication methods, the unique invoice coding rule, and the procedures for reporting invoice acceptance, rejection, payment, and collection.
The Order requires AEAT to make the public platform available at least two months before the first compliance date applies, which points to a platform availability date of 6 August 2027 at the latest.
Businesses and professionals in scope should review the technical requirements in this Order now, since they define the invoice format the mandate will require.
