What did AEAT announce about Spain’s e-invoicing mandate on 10 September 2026?
No start date has moved, and none of them is fixed in law yet, because the order that starts the clock has not been published.
Oct 2026
Target for publishing the order, repeated
AEAT webinar, 10 September 2026
1 Oct 2027
First wave, expected: above EUR 8 million
1 Oct 2028
Second wave, expected: everyone else
Still a draft
Status of the order as at 14 September 2026
Spain’s tax authority has repeated its plan to publish the ministerial order behind the country’s B2B e-invoicing mandate in October 2026. It gave the update at a webinar on 10 September 2026, where it also showed parts of the technical specification for the platform.
The order sets the technical framework for the mandate created by the Crea y Crece law of 2022 and built out by Royal Decree 238/2026. AEAT plans to open the test environment and publish the developer documentation around the same time as the order, though neither can happen until the order is officially published.
The timetable itself is unchanged. Every deadline runs from the day the order takes effect, so the whole sequence moves if publication slips.
When does Spain’s B2B e-invoicing mandate start?
Businesses above EUR 8 million come in twelve months after the order takes effect, expected 1 October 2027. Everyone else follows at twenty four months, expected 1 October 2028, and reporting for the smallest taxpayers completes at thirty six months, expected 1 October 2029.
The two outside steps are done: the public consultation closed in May 2026 and the European Commission notification in August 2026. Only publication is left, and Spanish law requires a rule like this to be published before it can take effect.
| Milestone | Status |
|---|---|
| Public consultation on the draft order | Closed 8 May 2026 |
| European Commission notification and waiting period | Closed 6 August 2026 |
| AEAT technical update | Held 10 September 2026 |
| Order published, with documentation and test environment to follow | Targeted October 2026 |
| Wave 1: above EUR 8 million | 1 October 2027 |
| Wave 2: all remaining businesses | 1 October 2028 |
| Wave 3: reporting for the smallest taxpayers | 1 October 2029 |
The ministerial order takes effect
The draft order sets its own entry into force at 1 October 2026, and says that this is the date from which the transitional periods start to run. It is the only date in the calendar that is fixed by the text rather than counted from something else.
- After publicationOctober 2026
Integration test environment opens
Businesses and providers can test against the platform. It does not open before the order is published.
- Anchor + 12 months1 October 2027
Wave 1: the largest businesses
Businesses above the EUR 8 million VAT threshold start issuing e-invoices and reporting status and payment.
- Anchor + 24 months1 October 2028
Wave 2: everyone else
All remaining businesses start issuing. Reporting starts too, except for sole traders and partnership-type entities.
- Anchor + 36 months1 October 2029
Wave 3: reporting completes
Sole traders and partnership-type entities below the threshold start reporting status and payment.
The transitional periods in Royal Decree 238/2026 are counted from the order taking effect, so if the anchor moves, the dates below it move with it by the same interval. The draft also requires the platform to be available on AEAT’s electronic office at least two months before the order is first applied, which is around 1 August 2027 as drafted.
Only the date the order takes effect stands on its own. Every other date is counted from it.
Who has to comply, and when?
Which wave a business falls into depends on its volume of operations, a VAT figure rather than the turnover shown in the accounts, and the two can differ. Issuing and reporting do not always start together either: sole traders and partnership-type entities begin issuing in October 2028 but get a further year before they have to report invoice status and payment.
Volume of operations above EUR 8 million
A VAT figure, not accounts turnover, for the calendar year before the order takes effect.
Issue and receive e-invoices
1 October 2027
Report status and payment
1 October 2027
Companies at or below EUR 8 million
Legal persons outside the first wave.
Issue and receive e-invoices
1 October 2028
Report status and payment
1 October 2028
Sole traders and partnership-type entities at or below EUR 8 million
Individuals, and entities taxed through their members under the personal income tax regime.
Issue and receive e-invoices
1 October 2028
Report status and payment
1 October 2029
The dates assume the order takes effect on 1 October 2026. They are the twelve, twenty four and thirty six month periods in the transitional provisions of Royal Decree 238/2026, counted from that date.
The EUR 8 million test is volume of operations under the VAT law, not turnover as the accounts report it.
What did AEAT show about how the platform will work?
100
Invoices per submission
5,120 KB
Maximum per invoice
1,000
Records per lookup
100
Invoices per retrieval
The agency named the services businesses and software providers will use, and put numbers on them. Invoices are sent up in batches and can be searched for and pulled back down again, and buyers and sellers report separately on what happens to them. Files cannot be attached to an invoice, only linked to.
Every invoice then passes three checks: is the file built correctly, does it meet the European standard’s rules, and does it satisfy a Spanish layer covering tax logic and the required codes. Senders are expected to run the first two themselves. Passing all three means the invoice was accepted onto the platform. The briefing was explicit that this is not the same as the tax authority agreeing with what the invoice says.
| Service | What it does |
|---|---|
| Sending | Sends invoices up in batches, whether the original or a copy. |
| Cancelling | Withdraws an invoice that was sent in error. |
| Searching and downloading | Finds invoices on the platform and pulls them back. |
| Reporting what happened | Buyer and seller report separately, and either can undo a report made in error. |
- Check 1StructureSender runs it
Is the invoice file built correctly?
- Check 2European rulesSender runs it
Does it meet the rules behind the European standard?
- Check 3Spanish checksState platform
Spanish tax logic, internal consistency and the required codes.
All three passed: the invoice is accepted
Acceptance means the platform took the invoice in. The briefing was explicit that it is not the tax authority agreeing with what the invoice says.
Invoices in a batch are judged one by one, so a single bad document does not send the rest of the batch back.
What changed in Spain’s revised draft order?
The revisions bring the Spanish invoice closer to the European standard, and change what the invoice file has to contain. As at 14 September 2026, AEAT had not published the slides on its developer portal and the revised draft was not public, so the table reflects the briefing as presented.
| Area | What the revised draft does |
|---|---|
| Credit and debit notes | Drops the bespoke national construct for the European standard’s own way of referencing a corrected document, with the reason, the method and the corrected amounts. |
| Identifying the parties | Splits into three terms: VAT number, domestic tax number and commercial registry number, the registry entry being required wherever the domestic number is used. |
| Charges and deductions | Gains header and line placings, covering excise duties on fuels, alcohol, tobacco, electricity, single use plastics and waste levies, plus third party charges and withholdings. |
| Self-billing | Confirmed with its own document types, and issuing through a third party now triggers a required data group. |
| Cancelling an entry | A new cancellation message withdraws an invoice lodged in error, leaving a traceable record. It does not replace a credit note where the law requires one. |
What happens next?
The order has to be published, with the developer documentation and the test environment following. Testing cannot begin until the order is published. The draft also requires the platform to be available at least two months before the mandate first applies, which on current dates falls around August 2027.
On postponement: no published wave date has moved. Spain is running a second invoicing reform on its own timetable, and that one did move: Veri*factu now requires invoicing software to be adapted by 1 January 2027 for businesses that pay corporate income tax and by 1 July 2027 for everyone else. For the platform architecture behind all of this, see our write-up of the May developer seminar and the Spain e-invoicing guide. This page is updated as that material appears.
Agencia Estatal de Administración Tributaria, webinar “Actualización sobre la Solución Pública de Facturación Electrónica (SPFE)”, held 10 September 2026 and announced on the AEAT developer portal on 29 July 2026. The agenda covers an update on the draft ministerial order and its annexes, followed by technical information on the platform’s services with examples.
Ministerio de Hacienda, draft Orden Ministerial regulating the Solución Pública de Facturación Electrónica, version of 16 April 2026 with its annexes. Article 4 covers the faithful copy and the prohibition on attachments; article 5 submission, validation and rejection, with four days allowed after a technical fault is resolved; article 7 payment reporting; article 10 authentication and representation. The sole additional provision requires the platform to be available at least two months before the order is first applied, and the sole final provision sets entry into force at 1 October 2026.
Real Decreto 238/2026, de 25 de marzo, published in the BOE of 31 March 2026 and in force from 20 April 2026. The fourth final provision counts twelve and twenty four months from the ministerial order taking effect; transitional provision two defines the EUR 8 million volume of operations by reference to article 121 of Ley 37/1992; transitional provision three adds a further twelve months for status reporting by individuals and income attribution entities.
Ley 18/2022, de 28 de septiembre, de creación y crecimiento de empresas, in force from 19 October 2022, which created the duty to issue electronic invoices between businesses and professionals.
Ley 39/2015, de 1 de octubre, article 131, which requires regulations to be published in the corresponding official gazette in order to enter into force and produce legal effects.
Real Decreto-ley 15/2025, which moved the Veri*factu software adaptation deadline to 1 January 2027 for corporate income tax filers and 1 July 2027 for other taxpayers.
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