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The draft Ministerial Order and its status communication requirements

Regulatory17 April 20262 replies12 likesLast post 18 April 2026Reply

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Jean D.17 April 2026

Reading through the draft Ministerial Order published on Monday and a few things stand out. The mandatory status communication requirement is more granular than I expected, separate flags for acceptance, rejection and effective payment, all transmitted to AEAT. That is going to put real pressure on AP/AR systems that currently treat payment status as an internal field. Also worth flagging, the EU aligned structured format requirement explicitly rules out PDF and Excel, even as a parallel copy. Has anyone here started benchmarking the volume implications for the AEAT public platform once all sub 8M businesses come on board?

Carlos S.18 April 2026

The payment status reporting bit is going to cause headaches for smaller clients still on legacy accounting tools. Most of my book do not have an automated way to flag effective payment back to the invoice, it is reconciled manually each month.

Marie L.18 April 2026

On the volume question, the AEAT consultation deck pegs steady state volumes at roughly 1.6 to 1.8 billion invoices per year once everyone is included. The platform is being built to handle that with surge capacity, but the realistic concern is the onboarding period in the second half of 2027 when the >8M cohort goes live, that is where the throughput will get tested.

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