Spain’s B2B e-invoicing: rules still due October 2026, start dates unchanged

What did AEAT announce about Spain’s e-invoicing mandate on 10 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 has said the test environment will not open before the order is published, and that developer documentation will go on its developer portal before the test environment does.

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. Sole traders and partnership-type entities then start reporting invoice status and payment 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.

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.

What did AEAT show about how the platform will work?

The agency named the services businesses and software providers will use, and the limits on each, set out in the table below. The slides have not been published, so these figures are as presented at the session. 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.

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.

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.