Spain e-Invoicing Guide

Spain is implementing a multi-layered e-invoicing framework. B2G has been mandatory since January 2015 through the FACe platform. On 24 March 2026, the Council of Ministers approved Royal Decree 238/2026 implementing the Crea y Crece Law (Law 18/2022) , making B2B e-invoicing mandatory. The decree was officially published in the BOE (Boletín Oficial del Estado) on 31 March 2026, and entered into force on 20 April 2026 (20 days after publication). On 16 April 2026, the Ministry of Finance published the draft Ministerial Order that sets the operational and technical rules for the AEAT public platform, opening a public consultation running until 8 May 2026. The draft sets the Order's operational start at 1 October 2026 (subject to change); the first business compliance deadline falls 12 months later for companies with turnover above EUR 8 million (projected October 2027), and 24 months later for all remaining businesses (projected October 2028). A free public platform operated by the AEAT will be available alongside interoperable private platforms.

On 1 June 2026, AEAT published two documents from its developer seminar of 19 May 2026, giving the first complete functional and technical picture of the public platform, the Solución Pública de Facturación Electrónica (SPFE): a functional overview of the draft Ministerial Order and a deck covering the technical aspects of the SPFE . The platform will work exclusively with UBL syntax aligned to EN 16931:2026, the March 2026 revision of the European standard based on UBL 2.5, which covers Spanish national cases such as withholdings and the equivalence surcharge. Validation has two layers, XSD for syntax and Schematron for business rules, and must be carried out by the sender before submission because AEAT will not offer a production validation service. The documents also set out a reference calendar: the Ministerial Order enters into force on 1 October 2026, and compliance starts on 1 October 2027 for companies with turnover above EUR 8 million.

The functional document confirms how Spain's hybrid model will operate in practice. Invoices issued or exchanged outside the SPFE must be deposited there as a faithful copy (copia fiel) simultaneously with issuance, flagged via the CopyIndicator field. Every invoice carries a unique code built from the issuer NIF, the series and number, and the issue date, which the platform uses to reject duplicates automatically. Recipients must report rejection where applicable (an invoice not rejected is presumed accepted in the SPFE), the date of full payment and the payment due date. Connectivity runs through synchronous web services with electronic certificate authentication. Sending is possible through a registered attorney-in-fact (apoderamiento) or a social collaborator, but retrieving invoices or statuses requires a power of attorney registered with AEAT, so automated retrieval without registered representation is blocked. An integration test environment opens once the Order is published in the BOE, with WSDLs, XSD schemas, Schematron files and message examples published on the AEAT developer portal beforehand.

In parallel, Spain has introduced Veri*factu, a real-time invoice reporting system managed by the AEAT (Agencia Estatal de Administración Tributaria). Following delays, Veri*factu is now mandatory from January 2027 for corporate income tax payers and July 2027 for self-employed taxpayers. The system requires certified invoicing software that reports billing records to AEAT as each invoice is generated.

Spain's B2G mandate via FACe has been in place since January 2015. The Crea y Crece Law was enacted in December 2022, and the implementing Royal Decree 238/2026 was approved by the Council of Ministers on 24 March 2026, then officially published in the BOE on 31 March 2026. The decree entered into force on 20 April 2026. On 16 April 2026, the Ministry of Finance published the draft Ministerial Order for public consultation (open until 8 May 2026). Veri*factu was postponed to 2027 (separate regulation). Companies already on the SII real-time reporting system are exempt from Veri*factu.

AEAT's seminar documentation published on 1 June 2026 sets out a reference calendar for the B2B rollout. The Ministerial Order enters into force 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, and natural persons and income-attribution entities begin payment reporting on 1 October 2029. These dates remain subject to publication of the final Order in the BOE, expected on 1 October 2026.

All suppliers to the Spanish public sector must submit invoices electronically through FACe in the FacturaE format. For B2B, the Royal Decree implementing the Crea y Crece Law mandates structured electronic invoices for all businesses, phased by size. PDF and Excel files are not considered valid electronic invoices. Recipients must report rejection where applicable (an invoice not rejected is presumed accepted in the SPFE), the date of full payment and the payment due date; issuers may report collection, non-payment or differences against the dates the recipient communicated.

Veri*factu requires compliant invoicing software that reports invoice data to AEAT in real-time. B2C transactions are not covered by the B2B e-invoicing mandate but may be captured by Veri*factu reporting. Cross-border invoices follow EU ViDA rules.

Spain uses different systems for B2G and B2B. B2G invoices flow through FACe, the central government procurement platform, using the FacturaE format. B2B invoices will be exchanged via the free public platform (SPFE) operated by the AEAT (Tax Agency) or through private platforms, which must interoperate with all market platforms to prevent vendor lock-in. Under Royal Decree 238/2026, the AEAT public platform must be available at least 2 months before the first compliance deadline. The SPFE itself works exclusively with UBL syntax aligned to EN 16931:2026 (UBL 2.5); private platforms may exchange other structured formats between themselves, but the faithful copy deposited in the SPFE must follow the semantics, syntax and specifications the platform defines.

The AEAT technical documentation also sets clear expectations for private platforms. They must aggregate traffic rather than operating invoice by invoice or client by client, hold a registered power of attorney (apoderamiento) per client to retrieve invoices or statuses on their behalf, and retrieve exchanged invoices automatically with immediate availability to their clients. AEAT is explicit that the SPFE is not an ERP module, a backup system for a private platform, or free cloud storage for invoices. For a diagram-led walkthrough of the architecture, see our SPFE technical deep dive .

Veri*factu operates as a real-time reporting layer. Invoicing software must be certified to report invoice data to AEAT as each invoice is generated. This is separate from the invoice exchange itself and acts as a digital audit trail.

Spain enforces B2G compliance through invoice rejection on FACe. For B2B, penalties under the Crea y Crece Law can reach up to EUR 10,000 per infraction for failing to issue or accept structured e-invoices. Businesses using non-compliant invoicing software face fines of up to EUR 50,000 per year, and software vendors selling non-compliant systems risk penalties of up to EUR 150,000 per year per product.