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Spain e-Invoicing
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Spain has required Facturae invoices via FACe from public sector suppliers since January 2015. Royal Decree 238/2026 sets out the phased B2B mandate under Law 18/2022, and Order HAC/1028/2026 started its clock on 6 October 2026. Businesses above EUR 8 million turnover follow on 6 October 2027 and all others on 6 October 2028.
Previous
3 December 2025B2B
Veri*factu deadlines deferred to 2027
Latest
5 October 2026B2B
Order HAC/1028/2026 starts the B2B e-invoicing clock
Next
1 January 2027
ViDA: deemed supplier extension, OSS and IOSS changes
Spain e-Invoicing OverviewViDA
B2B
phased
since 19 October 2022Phased B2B mandate under Law 18/2022 (Crea y Crece), developed by Royal Decree 238/2026 and in force since 20 April 2026. It applies where the recipient of the transaction has its business seat, a permanent establishment or its habitual residence in Spain. Order HAC/1028/2026, which regulates the AEAT public solution, took effect on 6 October 2026: obligations apply twelve months later where the volume of operations exceeded EUR 8 million in the previous calendar year, and twenty-four months later for everyone else. Sole traders and income-attribution entities at or below the threshold get a further year, to October 2029, before reporting invoice status and payment. Large companies must attach a legible PDF copy for their first twelve months unless the recipient accepts the structured original.
B2G
mandatory
since 15 January 2015Suppliers to the public sector must invoice electronically under article 4 of Law 25/2013, in force since 15 January 2015. The duty binds public limited and limited liability companies, legal persons without Spanish nationality, permanent establishments and branches of non-residents, temporary business groupings and various funds, while other suppliers may do so by choice. Administrations may exclude invoices of up to EUR 5,000. Invoices use the Facturae format with an advanced electronic signature and go through the general entry point of the administration concerned, which is FACe for central government.
B2C
none
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Implementation Timeline(18 events)
Key mandate dates. Select a date for detail, or show all updates below.
Facturae mandatory for public sector suppliers
15 January 2015
B2G
Law 18/2022 (Crea y Crece) creates the B2B basis
28 September 2022
Domestic B2B
Law 18/2022 rewrites article 2 bis of Law 56/2007 so that all businesses and professionals must issue, send and receive electronic invoices with each other and report the states of those invoices. It was published on 29 September 2022 and entered into force on 19 October 2022, leaving the compliance dates to later regulation.
Veri*factu deadlines deferred to 2027
3 December 2025
B2B
Royal Decree-Law 15/2025 rewrites the final provision of the invoicing systems regulation, giving corporate income tax filers until 1 January 2027 and other taxpayers until 1 July 2027 to adapt their invoicing software, as set out in the AEAT nota informativa . Royal Decree-Law 16/2025 then opened a waiver window for SII and REDEME from 26 December 2025 to 31 January 2026, which lapsed when Congress repealed that decree on 28 January 2026.
Council of Ministers approves the B2B e-invoicing Royal Decree
24 March 2026
Legislative
Council of Ministers approves the Royal Decree implementing Law 18/2022 (Crea y Crece) , staging compliance one year after the pending Ministerial Order for companies above EUR 8 million turnover and two years for all others. The Ministry of Economy expected that Order before 1 July 2026 , a date that passed without publication.
Draft Ministerial Order opens for public consultation
16 April 2026
Legislative
AEAT publishes SPFE functional and technical documentation
1 June 2026
B2B
AEAT publishes two documents from its 19 May 2026 developer seminar giving the first complete picture of the public e-invoicing platform (SPFE): a functional overview of the draft Ministerial Order and the SPFE technical aspects . The SPFE will work exclusively with UBL syntax aligned to EN 16931:2026 (UBL 2.5). Senders must validate invoices against the published XSD schemas and Schematron business rules before submission, as no production validation service will be offered. Connectivity is via synchronous web services with electronic certificate authentication, and retrieval of invoices or statuses requires a power of attorney (apoderamiento) registered with AEAT. Faithful copies (copia fiel) of invoices exchanged outside the SPFE must be deposited simultaneously with issuance, flagged via the CopyIndicator field, and each invoice carries a unique code (issuer NIF, series and number, and issue date) enabling automatic deduplication.
AEAT publishes the SPFE seminar questions and answers
9 July 2026
B2B
AEAT posts the questions and answers from its 19 May 2026 seminar on the developer portal. The answers confirm that the public solution will take only UBL 2.5 invoices, so an invoice filed to FACe in Facturae still needs a faithful copy in UBL, that simplified invoices fall outside Royal Decree 238/2026 unless they are qualified, and that the test environment and technical specifications are expected before 1 October 2026.
AEAT announces a September update session on the SPFE
29 July 2026
B2B
Order HAC/1028/2026 enters into force
6 October 2026
B2B
Order HAC/1028/2026 , published in the BOE on 5 October 2026, regulates the AEAT public e-invoicing solution (SPFE) and takes effect the next day, starting the periods set in Law 18/2022 and Royal Decree 238/2026. Its annexes set the invoice fields under UBL and EN 16931 and the messages for payment, rejection, collection and non-payment. Use of the SPFE is free, and AEAT said in May 2026 that its integration test environment opens once the Order is published.
ViDA: deemed supplier extension, OSS and IOSS changes
1 January 2027
EU Level
B2B e-invoicing starts above EUR 8 million turnover
6 October 2027
B2B
Businesses whose volume of operations exceeded EUR 8 million in the previous calendar year must issue and receive structured e-invoices and report invoice status and payment, twelve months after Order HAC/1028/2026 took effect. The obligations on private e-invoicing platforms apply from the same date.
ViDA: platform obligations and single VAT registration
1 July 2028
EU Level
The single VAT registration reforms, the special scheme for transfers of own goods and the mandatory reverse charge for suppliers not identified in the member state of taxation take effect under Council Directive (EU) 2025/516 . The deemed supplier rule for short-term accommodation and passenger transport platforms runs on a wider window: member states apply it from 1 July 2028 at the earliest and 1 January 2030 at the latest.
B2B e-invoicing extends to all remaining businesses
6 October 2028
B2B
Payment reporting starts for sole traders and income-attribution entities
6 October 2029
B2B
ViDA: extended deadline expires for existing domestic reporting systems
1 January 2035
Domestic
The longer deadline in Council Directive (EU) 2025/516 runs out for member states that already had a domestic real-time transaction reporting obligation on 1 January 2024, or that had been authorised or had legislated for one before that date. Their domestic e-invoicing and reporting must follow the EU model from this point.
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Compliance Regime
Tax Authority
CTC Model
Centralised platform
Invoices move through private exchange platforms, the AEAT public solution (SPFE) or a combination of the two, and a business that has not agreed a private platform with its suppliers counts as having chosen the SPFE. Admitted syntaxes are CII, UBL, the EDIFACT invoice message and the Facturae message, each carrying the EN 16931 semantic model, and every invoice issued through a private platform must be signed with an advanced electronic signature. The SPFE itself accepts only UBL 2.5 aligned to EN 16931:2026, so a platform that issues elsewhere deposits a faithful copy (copia fiel) in UBL at the moment of issue, marked as a copy and without embedded files. Each invoice carries a unique code built from the issuer NIF, the invoice series and number and the issue date, which the platform uses to strip duplicates. Recipients report commercial acceptance or rejection with its date, and full effective payment with its date, within four calendar days excluding Saturdays, Sundays and national holidays. Partial acceptance or rejection, partial payment and assignment of the invoice to a third party are optional states, and an invoice that is not rejected is presumed accepted. Recipients also report full effective payment or rejection to the SPFE itself, whichever platform carried the invoice, giving the effective payment date and the payment due date; they may add the date goods or services were received, or the date the invoice arrived, where that matters under the late payment rules. Issuers may report collection, non-payment or differences from the dates the recipient gave. Private platforms must accept interconnection requests from any other platform in the system, may fall back on the SPFE as the interconnection node, and must meet operating requirements including ISO/IEC 27001 certification. Access uses electronic certificates, and retrieving invoices or states for a client requires social collaboration or a power of attorney (apoderamiento) registered with AEAT. Senders validate against the published XSD schemas and Schematron rules because AEAT will not run a production validation service.
Standards
EN 16931
Record-keeping & Reporting
Archiving
Four years for tax purposes under article 29.2 of Law 58/2003, as set out by the Agencia Tributaria ; six years for commercial records under the Commercial Code. Electronic storage is permitted, and storage in a third country that has no mutual assistance instrument with Spain must be communicated to AEAT beforehand.
SAF-T
Not required
SII (Suministro Inmediato de Información) used for near-real-time VAT reporting for certain taxpayers.
Technical Formats
Facturae
UBL 2.5
CII
EDIFACT
Penalties
Failure to Offer Electronic Invoicing
A warning or a fine of up to EUR 10,000 for companies that, being obliged to do so, do not offer users the option of receiving electronic invoices or do not let former customers reach their invoices, under article 2 bis.9 of Law 56/2007 as rewritten by article 12 of Law 18/2022 . The same fine reaches providers of services of special economic significance that breach the other duties in article 2.1.
Holding Non-Certified Invoicing Software
A fixed fine of EUR 50,000 for each year in which a business holds invoicing systems that are not certified when certification is required, or that have been altered, under article 201 bis of Law 58/2003 . The requirement comes from the invoicing systems regulation behind Veri*factu rather than from the B2B mandate.
Producing or Marketing Non-Compliant Software
A fixed fine of EUR 150,000 for each financial year with sales and for each type of system, for making, producing or marketing invoicing software that does not meet the requirements of article 201 bis of Law 58/2003 , dropping to EUR 1,000 for each system marketed without the certificate where certification is the only failing.
Exemptions
Simplified Invoices
Energy Market Operators
Latest Update
Timeline Update
5 Oct 2026Order HAC/1028/2026 starts the B2B e-invoicing clock
The Ministry of Finance published Order HAC/1028/2026 in the BOE on 5 October 2026. It regulates the AEAT public e-invoicing solution and takes effect on 6 October 2026, which fixes the Royal Decree 238/2026 dates: 6 October 2027 for businesses above EUR 8 million volume of operations and 6 October 2028 for all others.
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Reading through the draft Ministerial Order published on Monday and a few things stand out. The mandatory status communication requirement…
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Frequently asked questions about e-Invoicing in Spain
Yes, e-Invoicing is mandatory in Spain for B2G (since 15 January 2015) transactions.
B2B e-Invoicing in Spain is in a phased rollout since 19 October 2022. Phased B2B mandate under Law 18/2022 (Crea y Crece), developed by Royal Decree 238/2026 and in force since 20 April 2026. It applies where the recipient of the transaction has its business seat, a permanent establishment or its habitual residence in Spain. Order HAC/1028/2026, which regulates the AEAT public solution, took effect on 6 October 2026: obligations apply twelve months later where the volume of operations exceeded EUR 8 million in the previous calendar year, and twenty-four months later for everyone else. Sole traders and income-attribution entities at or below the threshold get a further year, to October 2029, before reporting invoice status and payment. Large companies must attach a legible PDF copy for their first twelve months unless the recipient accepts the structured original.
B2G e-Invoicing in Spain is mandatory since 15 January 2015. Suppliers to the public sector must invoice electronically under article 4 of Law 25/2013, in force since 15 January 2015. The duty binds public limited and limited liability companies, legal persons without Spanish nationality, permanent establishments and branches of non-residents, temporary business groupings and various funds, while other suppliers may do so by choice. Administrations may exclude invoices of up to EUR 5,000. Invoices use the Facturae format with an advanced electronic signature and go through the general entry point of the administration concerned, which is FACe for central government.
Spain supports the following e-Invoice formats: Facturae, UBL 2.5, CII, EDIFACT.
Spain uses the following e-Invoicing standards: EN 16931. Archiving requirement: Four years for tax purposes under article 29.2 of Law 58/2003, as set out by the Agencia Tributaria ; six years for commercial records under the Commercial Code. Electronic storage is permitted, and storage in a third country that has no mutual assistance instrument with Spain must be communicated to AEAT beforehand.
Invoices move through private exchange platforms, the AEAT public solution (SPFE) or a combination of the two, and a business that has not agreed a private platform with its suppliers counts as having chosen the SPFE. Admitted syntaxes are CII, UBL, the EDIFACT invoice message and the Facturae message, each carrying the EN 16931 semantic model, and every invoice issued through a private platform must be signed with an advanced electronic signature. The SPFE itself accepts only UBL 2.5 aligned to EN 16931:2026, so a platform that issues elsewhere deposits a faithful copy (copia fiel) in UBL at the moment of issue, marked as a copy and without embedded files. Each invoice carries a unique code built from the issuer NIF, the invoice series and number and the issue date, which the platform uses to strip duplicates. Recipients report commercial acceptance or rejection with its date, and full effective payment with its date, within four calendar days excluding Saturdays, Sundays and national holidays. Partial acceptance or rejection, partial payment and assignment of the invoice to a third party are optional states, and an invoice that is not rejected is presumed accepted. Recipients also report full effective payment or rejection to the SPFE itself, whichever platform carried the invoice, giving the effective payment date and the payment due date; they may add the date goods or services were received, or the date the invoice arrived, where that matters under the late payment rules. Issuers may report collection, non-payment or differences from the dates the recipient gave. Private platforms must accept interconnection requests from any other platform in the system, may fall back on the SPFE as the interconnection node, and must meet operating requirements including ISO/IEC 27001 certification. Access uses electronic certificates, and retrieving invoices or states for a client requires social collaboration or a power of attorney (apoderamiento) registered with AEAT. Senders validate against the published XSD schemas and Schematron rules because AEAT will not run a production validation service.
Spain has penalties for e-Invoicing non-compliance. Failure to Offer Electronic Invoicing: A warning or a fine of up to EUR 10,000 for companies that, being obliged to do so, do not offer users the option of receiving electronic invoices or do not let former customers reach their invoices, under article 2 bis.9 of Law 56/2007 as rewritten by article 12 of Law 18/2022; Holding Non-Certified Invoicing Software: A fixed fine of EUR 50,000 for each year in which a business holds invoicing systems that are not certified when certification is required, or that have been altered, under article 201 bis of Law 58/2003; Producing or Marketing Non-Compliant Software: A fixed fine of EUR 150,000 for each financial year with sales and for each type of system, for making, producing or marketing invoicing software that does not meet the requirements of article 201 bis of Law 58/2003, dropping to EUR 1,000 for each system marketed without the certificate where certification is the only failing.
Yes. Spain falls within the EU's VAT in the Digital Age (ViDA) package, adopted as Council Directive (EU) 2025/516 on 11 March 2025. ViDA makes structured e-invoicing and transaction-level digital reporting mandatory for intra-EU B2B supplies from 1 July 2030, and it already lets member states mandate domestic e-invoicing without first seeking a derogation.
The next e-Invoicing deadline in Spain is 1 January 2027: ViDA: deemed supplier extension, OSS and IOSS changes. Council Directive (EU) 2025/516 extends the deemed supplier rule for electronic interfaces in Article 14a of the VAT Directive and reworks the One Stop Shop, non-Union and Import One Stop Shop schemes.
Exemptions from Spain e-Invoicing may apply to: Simplified Invoices, Energy Market Operators, IATA Settlement Systems. Check specific criteria as exemptions vary by transaction type and business size.