Spain has initiated a public consultation from 17 April to 8 May 2026 on a Draft Order that regulates the public B2B electronic invoicing solution. This Draft Order implements the Third Final Provision of Royal Decree 238/2026 and amends the invoicing framework under Royal Decree 1619/2012. 

The regulation sets out the technical and functional rules governing the public platform, including invoice issuance and interconnection, submission of faithful copies, unique invoice identification codes, payment status reporting, and mandatory interoperability with private e-invoicing platforms.

The Order will take effect on 1 October 2026. It will be a phased rollout of mandatory B2B e-invoicing starting 1 October 2027 for large taxpayers and 1 October 2028 for other businesses. Specific transitional regimes will apply for smaller taxpayers and platforms.

What is the background and legislative context?

This Draft Order arises from a series of legislative measures aimed at modernising commercial transactions and reducing late payments in Spain. 

Law 18/2022 introduced mandatory B2B electronic invoicing and emphasised reliable payment period information to combat commercial late payments. 

Law 56/2007 was amended to include the mandatory e-invoicing system and tasked the Spanish Tax Agency (AEAT) with developing a public electronic invoicing solution. 

The Royal Decree 238/2026 further developed the mandatory e-invoicing system and empowered the Minister of Finance to regulate the technical elements of the public solution through this Order. The foundational invoicing regulation, Royal Decree 1619/2012, is being modified and supplemented accordingly.

The Draft Order outlines the features of the public electronic invoicing solution, covering services such as invoice issuance, interconnection, payment communication, and retrieval. 

It details the technical aspects of the accurate copy sent to the public solution, including unique codes and messages for payment status updates.

The Order also establishes authentication, identification, and representation procedures for accessing the public platform.

Features of the public electronic invoicing solution

The AEAT will develop and manage the public solution, which will serve as a universal and mandatory repository for all electronic invoices issued, sent, or received. 

The platform will provide electronic invoicing services to businesses and professionals who opt to use it, acting as an alternative, especially beneficial for SMEs. It will facilitate interconnections between private e-invoicing platforms to ensure interoperability. 

A key function is monitoring payment information to control late payments. Access to the platform and its services will be free for users.

All businesses and professionals must issue, send, and receive electronic invoices in their commercial relations with other businesses and professionals. They are required to provide information on invoice statuses. Businesses may use private platforms, the public solution, or both for issuing and receiving e-invoices. 

Those using private platforms have to simultaneously send a faithful electronic copy of each invoice to the public solution, adhering to the UBL syntax and containing semantically equivalent information. 

Recipients need to electronically communicate full payment or rejection of invoices to the public solution, while senders may voluntarily report collection or non-payment.

More on technical specifications and procedures

E-invoices must follow the EN16931 semantic data model using UBL syntax, as specified in the Order’s annex. Each invoice will have a unique code created from the issuer’s tax ID, invoice number, series, and issue date.

Attachments other than electronic signatures are prohibited. Submission methods include web forms for individual invoices and web services for interconnections and faithful copy submissions. Submissions will be checked for syntax and semantics, and you will receive a response indicating whether your submission was accepted or rejected.

A verification code will be issued after successful submission. There are processes in place to correct or cancel invoices and payment communications. 

Extensions for submission deadlines may be granted in case of technical issues.

Recipients provide payment statuses electronically, and private platforms need to quickly access and make invoices available. 

Access requires electronic authentication, mainly through valid certificates or the Cl@ve system, with authorised third parties allowed to represent.

A glance at the the implementation timeline

The Order begins on 1 October 2026, with the public solution required by 1 August 2027. E-invoicing is mandatory for businesses with an annual turnover over €8 million starting 1 October 2027, and for all other businesses from 1 October 2028.

Private platform obligations start on 1 October 2027. From 1 October 2027 to 1 October 2028, large businesses must send e-invoices with readable PDFs unless recipients accept the original format. 

Payment status reporting for small entities or individuals with a turnover below €8 million begins on 1 October 2029.

The Draft Order imposes no extra budgetary or administrative burdens beyond Royal Decree 238/2026. 

It follows the principles of necessity, efficacy, proportionality, legal certainty, transparency, and efficiency. Data processing will comply with the EU General Data Protection Regulation, Spain’s Organic Law on Personal Data Protection, and the National Security Scheme.