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Royal Decree 238/2026 in the BOE: which date to plan around

Regulatory1 April 20262 replies10 likesLast post 2 April 2026Reply

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Marcus W.1 April 2026

Glad to see Royal Decree 238/2026 finally in the BOE. For those of us running operations across several Spanish entities, the headline date everyone is quoting (20 April entry into force) is not really the one to plan around. The Treasury ministerial order is what kicks off the 1 year clock for the larger turnover bracket, and AEAT's public platform only has to be live two months before the first compliance date, which leaves a fairly narrow window for proper integration testing. Anyone already mapping their ERP output to the structured formats?

Carlos S.2 April 2026

Quick one, does the 1 year window start from the Royal Decree, or from when the ministerial order is published? Most of my SME clients sit well below the 8M threshold so they get the 2 year version, but the timing on when those 2 years begin matters quite a lot for planning.

Hans B.2 April 2026

From the ministerial order, not the Royal Decree. The Decree sets the framework, the Ministerial Order (expected before 1 July 2026 based on AEAT's public consultation) is what actually triggers the timer. So in practice you are looking at compulsory compliance for the >8M cohort from around mid 2027, and the rest of B2B from mid 2028. We have already started internal mapping for our Spanish subsidiaries and the structured format requirement is going to need a chunk of rework for anything currently living as PDF.

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