Fiscal subject related
Spain has taken another step toward mandatory B2B electronic invoicing under the Crea y Crece Law (Law 18/2022). The Ministry of Finance has published a draft ministerial order regulating the public e-invoicing platform, opening it to public consultation.
The draft order outlines how the system, managed by the Spanish Tax Agency (AEAT), will work in practice. It sets operational and technical rules, including:
· How businesses issue and receive invoices through the AEAT platform.
· Transmission of invoice data when private platforms are used.
· Communication of mandatory invoice statuses (acceptance, rejection, payment).
· Interoperability between public and private platforms.
· Identification and authentication requirements for users.
· Use of structured formats aligned with EU standards.
Once approved, the order will trigger the phased rollout of mandatory e-invoicing. Large companies will be required to comply first, followed later by smaller businesses after a transition period.
The consultation is open until May 8, 2026, giving companies and software providers the chance to provide feedback. The Order is scheduled to enter into force on 1 October 2026, triggering the phased rollout of mandatory B2B e‑invoicing from 1 October 2027 (large taxpayers) and 1 October 2028 (other businesses), with specific transitional regimes for smaller taxpayers and platforms, though this date may change.
At this stage, the draft has no binding effect, and its final content will depend on the outcome of the consultation.
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