Spain e-Invoicing Guide

Spain runs three separate regimes that are easy to confuse. Public sector suppliers have filed Facturae invoices through FACe since 15 January 2015 under Law 25/2013 . Business-to-business e-invoicing rests on article 12 of the Crea y Crece Law (Law 18/2022) , which rewrote article 2 bis of Law 56/2007 so that every business and professional must issue, send and receive electronic invoices with each other and report their states. And Veri*factu, the invoicing software regime under Royal Decree 1007/2023, sits alongside both: it governs how invoicing software records and reports billing records to AEAT, whatever the invoice format.

The B2B mandate took shape in 2026. The Council of Ministers approved Royal Decree 238/2026 on 24 March, the BOE published it on 31 March, and it entered into force on 20 April. The decree does not set calendar dates. Its fourth final provision defers effective application to twelve months after a Ministerial Order regulating the AEAT public solution enters into force, for businesses whose turnover exceeded EUR 8 million in the previous calendar year, and twenty-four months after for everyone else. The Ministry of Finance published the draft Ministerial Order on 16 April 2026 with comments open until 8 May. When it approved the decree the Ministry of Economy expected the Order before 1 July 2026 ; the draft instead set its own entry into force at 1 October 2026, and at the start of September 2026 it had still not been published in the BOE.

AEAT filled in the technical picture over the summer. Two documents from its developer seminar of 19 May 2026, a functional overview and a deck on the technical aspects of the SPFE , describe a public platform that works only in UBL 2.5 aligned to EN 16931-1:2026, validates nothing on the sender's behalf, authenticates by electronic certificate, and demands a registered power of attorney before a platform can retrieve invoices or states for a client. The seminar's questions and answers , posted on 9 July, add that a Facturae invoice filed to FACe still needs a faithful copy in UBL, that FACe and the SPFE are not being merged, and that simplified invoices stay outside the decree unless they carry the recipient's details.

Veri*factu has its own clock. After Royal Decree-Law 15/2025 , corporate income tax filers must have adapted their invoicing software before 1 January 2027 and all other taxpayers before 1 July 2027, as AEAT sets out in its nota informativa . Businesses that keep their VAT books through SII are outside that regulation. AEAT is explicit that the two obligations are different in scope: e-invoicing covers domestic B2B transactions, while the software regulation reaches all invoicing done with software, including simplified invoices and sales to consumers.

Spain's B2G mandate via FACe has been in place since 15 January 2015. The Crea y Crece Law was published on 29 September 2022 and entered into force on 19 October 2022, leaving its e-invoicing article to later regulation. Royal Decree 238/2026 was approved by the Council of Ministers on 24 March 2026, published in the BOE on 31 March 2026 and entered into force on 20 April 2026. The draft Ministerial Order went out for consultation on 16 April 2026, open until 8 May 2026. Veri*factu was deferred to 2027 by Royal Decree-Law 15/2025 in December 2025; the extraordinary window to leave SII and REDEME that followed under Royal Decree-Law 16/2025 lapsed when Congress repealed that decree on 28 January 2026.

AEAT's seminar documentation of 1 June 2026 sets out a reference calendar for the B2B rollout, built on the draft Order taking effect on 1 October 2026. Companies with turnover above EUR 8 million must exchange e-invoices and report payment statuses from 1 October 2027. The remaining companies follow on 1 October 2028, when SME legal persons also begin payment reporting. Natural persons and income-attribution entities at or below EUR 8 million begin payment reporting on 1 October 2029; until then their state reporting is voluntary. Every one of these dates moves if the Order is published later than 1 October 2026, because the decree counts its clocks from the Order, not from the calendar.

The work stayed in public view through the summer. On 9 July 2026 AEAT posted the questions and answers from the 19 May seminar , which also say the integration test environment is expected for 1 October 2026 and that technical specifications will appear progressively on the AEAT electronic office before the services open. On 29 July it scheduled an update session on the SPFE for 10 September 2026, covering changes to the draft Order and its annexes. The Order had still not reached the BOE at the start of September 2026.

Under article 4 of Law 25/2013 , public limited and limited liability companies, legal persons without Spanish nationality, permanent establishments of non-residents, temporary business groupings and various funds must invoice the public sector electronically through the relevant general entry point, FACe for central government, in the Facturae format with an advanced electronic signature. Administrations may exclude invoices of up to EUR 5,000. When a public body buys as a business rather than as an administration, AEAT says the B2B decree applies to that transaction as well, and Law 25/2013 continues to apply on top.

For B2B, Royal Decree 238/2026 applies wherever the recipient has its business seat, a permanent establishment or its habitual residence in Spain. The invoice must be a structured message carrying the EN 16931 semantic model in one of four syntaxes: CII, UBL, the EDIFACT invoice message or the Facturae message. Simplified invoices are excepted unless they are qualified simplified invoices with the recipient's details. The second additional provision also carves out the regulated activities of the electricity market operator, the organised gas market operator, and invoices settled through the IATA CASS, BSP and SIS-ICH clearing systems. During their first twelve months, companies above EUR 8 million turnover must attach a legible PDF copy unless the recipient expressly accepts the structured original, and that PDF never goes to the public platform.

Invoice states run on two layers. To the supplier, 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. To the SPFE itself, whichever platform carried the invoice, recipients report full payment or rejection with the effective payment date and the payment due date. An invoice that nobody rejects, and that no later corrective invoice replaces, is presumed accepted. Veri*factu is a separate duty: certified invoicing software that produces chained, signed billing records, with consumer sales and simplified invoices inside its scope even though they sit outside the e-invoicing mandate.

Spain uses different systems for B2G and B2B. B2G invoices flow through FACe, the central government entry point, in the Facturae format. B2B invoices will move through private exchange platforms, the free public solution (SPFE) operated by AEAT, or a combination of the two. A business that has not agreed a private platform with its suppliers counts as having chosen the SPFE, and a recipient that has chosen a private platform must publish its entry point in its communications and on its website. Private platforms must transform between all four syntaxes, interconnect with any other platform on a client's request, move traffic over AS2 or AS4, and hold ISO/IEC 27001 or an equivalent certification, while the SPFE acts as the interconnection node when two platforms are not linked. Under the decree the public solution must be available at least two months before the first compliance date.

The SPFE works only in UBL 2.5 aligned to EN 16931-1:2026, so every invoice issued through a private platform is mirrored there as 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 series and number, and the issue date, which the platform uses to strip duplicates. Validation has two layers, XSD for syntax and Schematron for the business rules, and the sender must run both before submission because AEAT will not offer a production validation service. Connectivity runs through synchronous web services with electronic certificate authentication; a platform may send on a client's behalf as a social collaborator or attorney-in-fact, but retrieving that client's invoices or states requires a power of attorney (apoderamiento) registered with AEAT.

The AEAT technical documentation sets clear expectations for private platforms: aggregate traffic rather than operating invoice by invoice, retrieve exchanged invoices automatically with immediate availability to clients, and treat the SPFE as neither an ERP module, nor a backup for a private platform, nor free cloud storage. Payment communications reach the SPFE by web service or through an invoice-by-invoice web form, and AEAT answers each submission with an acknowledgement carrying a secure verification code. For a diagram-led walkthrough of the architecture, see our SPFE technical deep dive.

Spain enforces B2G compliance through invoice rejection on FACe. On the private side, article 2 bis.9 of Law 56/2007 , as rewritten by article 12 of the Crea y Crece Law, allows a warning or a fine of up to EUR 10,000 against 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. Royal Decree 238/2026 itself contains no sanctions, and the March 2026 Council of Ministers reference quotes no figures.

The software fines sit in a different regime. Article 201 bis of the General Tax Law sets a fixed EUR 50,000 per year for holding invoicing systems that should be certified and are not, and EUR 150,000 for each financial year with sales and each type of system for making or marketing non-compliant invoicing software, dropping to EUR 1,000 per system where the certificate is the only thing missing. Those two fines belong to the invoicing systems regulation behind Veri*factu, not to the B2B mandate.