Spain starts the B2B e-Invoicing clock

The Order

Spain’s B2B e-invoicing mandate now has fixed start dates. On 5 October 2026 the Ministry of Finance (Ministerio de Hacienda) published Order HAC/1028/2026 in the Official State Gazette (BOE), effective from 6 October 2026.

The Order sets out how the free public e-invoicing platform (SPFE) run by the Spanish Tax Agency (AEAT) will work. It is also the step the mandate was waiting for. The mandate comes from Law 18/2022, known as the Crea y Crece law, and under Royal Decree 238/2026 its deadlines are counted from 6 October 2026. Until 5 October the Order was still a draft.

The mandate dates

The mandate has two main dates. Businesses and professionals with an annual VAT turnover above EUR 8 million in the previous year must send and receive e-invoices from 6 October 2027. All other businesses and professionals follow from 6 October 2028.

The EUR 8 million test uses the volume of operations under Spanish VAT law for the previous calendar year.

Some earlier calendars show 1 October dates. They were based on the draft Order, which was due to take effect on 1 October 2026. The final Order is effective from 6 October 2026, so both dates fall on 6 October.

What the mandate means in practice

Once the mandate applies, B2B invoices in scope must be sent and received as structured e-invoices. Businesses can use AEAT’s public platform, which is free, or a private e-invoicing provider. Invoices sent through a private provider are also copied to AEAT.

Customers must also report the status of invoices they receive: whether they accept or reject them, and when they pay them in full. Self-employed individuals and partnership-type entities at or below EUR 8 million send and receive e-invoices from 6 October 2028, but this status reporting is voluntary for them until 6 October 2029.

For their first year in scope, businesses above EUR 8 million must also send a PDF copy with each e-invoice, unless the customer agrees to receive the e-invoice on its own. Private e-invoicing providers take on their own obligations from 6 October 2027. The technical detail behind the platform is covered in our SPFE technical write-up.

What comes next

AEAT must have the public platform ready at least two months before the first deadline of 6 October 2027. In September 2026 AEAT said its test environment would not open before the Order was published, gave October 2026 as the target, and said technical documentation would be released first. As at 5 October 2026, neither had been announced.

Veri*factu, Spain’s separate rules for invoicing software, runs on its own timetable, set out in our earlier post on the B2B mandate. The Spain country page tracks the mandate as it develops, and the Spain e-Invoicing guide covers scope, exemptions and penalties. Spain’s dates also appear on the global e-invoicing timeline, and the vendor directory can be filtered by country.