Spain sets final B2B e-invoicing timeline, with first mandate starting in October 2027

Spain has triggered the final countdown for mandatory B2B e-invoicing. Large businesses must comply from 6 October 2027, followed by most remaining businesses in October 2028, while certain self-employed taxpayers receive until October 2029 for invoice-status reporting.

Spain has taken a decisive step toward mandatory B2B electronic invoicing with the publication of the technical ministerial order governing the country's public e-invoicing solution.

On 5 October 2026, the Ministry of Finance published Order HAC/1028/2026 of 2 October in the Official State Gazette (BOE). The Order enters into force on 6 October 2026, and this date starts the countdown for the phased application of Spain's mandatory B2B e-invoicing regime. The Order can be found:

https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-20587&lang=es&utm_source 

The obligation originates from Law 18/2022 on the Creation and Growth of Companies, commonly known as the Crea y Crece Law. The detailed system was subsequently established through Royal Decree 238/2026 of 25 March, while the new ministerial order completes an important part of the technical framework for the public e-invoicing solution.

When does mandatory B2B e-invoicing start?

The implementation is divided according to the company's annual turnover.

Businesses and professionals whose turnover exceeded €8 million in the previous calendar year will fall under the mandatory system 12 months after the ministerial order enters into force. This means the first phase starts on:

• 6 October 2027 – businesses with annual turnover above €8 million.

For all other businesses and professionals, the Royal Decree provides a 24-month implementation period, meaning the obligation starts on:

• 6 October 2028 – remaining businesses and professionals.

There is an additional transitional measure for certain smaller self-employed taxpayers. Individuals and entities subject to the personal income tax attribution regime whose turnover does not exceed €8 million receive a further 12 months specifically for compliance with the obligation to communicate invoice statuses.

For these taxpayers, invoice-status reporting therefore becomes applicable from: 6 October 2029.

This distinction is important: the additional 2029 deadline concerns the invoice-status reporting obligation, rather than a general postponement of all e-invoicing requirements for self-employed taxpayers.

The Spanish system generally covers invoices issued between businesses and professionals where the recipient is established in Spain, has a permanent establishment in Spain, or, where applicable, has its domicile or habitual residence in Spain and the transaction relates to that Spanish presence. Businesses will be able to exchange invoices through private e-invoicing platforms, the public e-invoicing solution operated by the Spanish Tax Agency (AEAT), or a combination of both.Where a private platform is used, a faithful electronic copy of the invoice must also be transmitted to the public solution according to the prescribed requirements.

There are some exceptions. For example, ordinary simplified invoices are generally excluded from the mandatory B2B electronic-invoicing requirement, although qualified simplified invoices falling under the specific rules may remain in scope.

Order HAC/1028/2026 provides the technical and functional details needed for Spain's public electronic invoicing solution.

For invoices transmitted through the public solution, the Order requires the EN 16931 semantic model using UBL – Universal Business Language. The annexes specify the structure and mandatory data elements for electronic invoices and related messages.

The public system will be managed by the Spanish Tax Agency (AEAT) and will serve not only as an invoicing option but also as a central repository and interoperability point for invoices exchanged through private platforms.

The Order also requires the public solution to be available at least two months before the first mandatory phase begins, allowing businesses time to connect and test their processes.

One of the most important differences between ordinary electronic invoicing and Spain's new B2B system is that businesses will not only exchange structured invoices.

Recipients will also need to communicate specified invoice statuses.

Royal Decree 238/2026 requires recipients to report at least:

• commercial acceptance or rejection of the invoice and the relevant date; and
• full effective payment of the invoice and the actual payment date.

The new ministerial order defines the technical messages for communicating information such as payment and rejection through UBL-based messages. For example, the rejection message must contain the rejection date, reason and identification of the relevant invoice.

Businesses may also voluntarily exchange additional statuses, such as partial acceptance, partial payment or information about the transfer of the invoice to a third party for collection.

This means companies will need integration not only between their invoicing systems and e-invoicing platforms but also between accounts receivable, accounts payable and payment processes.

Large businesses entering the regime in October 2027 will also face a temporary transition rule

For the first 12 months after the regime becomes applicable to businesses with turnover above €8 million, electronic invoices must generally be accompanied by a PDF version that ensures readability.

The PDF requirement does not apply where the recipient expressly and voluntarily agrees to receive the invoice only in its original electronic format

The PDF is sent to the customer but is not sent to the public e-invoicing solution.

The transitional measure is designed to make the move to structured invoices easier for businesses whose systems may not yet be fully prepared to display or process the electronic format.

In our view, publication of this ministerial order is one of the most important milestones in Spain's B2B e-invoicing project because companies finally have a fixed starting point from which the implementation deadlines can be calculated.

The main challenge will not simply be generating an electronic invoice. Businesses must also integrate invoicing with payment and invoice-status processes and ensure interoperability with the public solution or their chosen private platform.

For retailers, the reform is particularly relevant where B2B invoices are generated from POS, ERP or back-office systems. Companies should therefore map which system creates the legal B2B invoice and where payment, rejection and acceptance information is stored.

Implementation impact and what the business should do:

Businesses with annual turnover above €8 million should prepare for mandatory B2B e-invoicing from 6 October 2027. Most remaining businesses and professionals follow from 6 October 2028, while certain smaller self-employed taxpayers receive until 6 October 2029 specifically for invoice-status reporting.

Companies should now review their ERP, invoicing, accounts payable and accounts receivable systems, determine whether they will use the AEAT public solution or a private provider, and ensure they can generate and process the required structured electronic invoice formats.

Businesses should also prepare to report invoice acceptance, rejection and payment information and should review how these statuses flow between finance, payment and invoicing systems.

Large businesses should additionally prepare for the temporary requirement to provide a readable PDF alongside the structured e-invoice during their first year of implementation.

For retailers, the key question is whether B2B invoices are generated through the POS or another system. Where POS systems generate legal B2B invoices, those systems or their connected invoicing modules will need to support the new structured invoicing and status-reporting workflow.

The source for this text above is based on an article that was published by Thomson Reuters. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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