Spain

Mandate 2027 Updated 2026-10-131 change this quarter

Baseline

Mandatory B2B electronic invoicing under Ley 18/2022 (Crea y Crece), developed by Real Decreto 238/2026 and Orden HAC/1028/2026

Spain will require electronic invoices between businesses and professionals, exchanged through private platforms or a free public solution run by the tax agency (AEAT). Real Decreto 238/2026 set the rules, and Orden HAC/1028/2026 (in force 6 Oct 2026) started the clock. As of October 2026 the obligation is not yet enforceable: it starts on 6 Oct 2027 for larger businesses and 6 Oct 2028 for the rest.

Key Dates

15 Jan 2015Public bodies must receive supplier invoices electronically; the FACe entry point is available (invoices under EUR 5,000 can be excluded)

1 Jul 2017SII (immediate VAT information supply) starts for large companies, monthly VAT filers and VAT groups

20 Apr 2026Real Decreto 238/2026 enters into force (published 31 Mar 2026); its application is deferred

6 Oct 2026Orden HAC/1028/2026 on the public solution enters into force and starts the compliance deadlines

6 Oct 2027B2B e-Invoicing applies to businesses and professionals with turnover above EUR 8 million in the previous year

6 Oct 2028B2B e-Invoicing applies to all other businesses and professionals

6 Oct 2029Individuals and income-attribution entities must report invoice status and payments

Who is in scope

All businesses and professionals issuing invoices to other businesses or professionals in Spain, phased by prior-year turnover (above or up to EUR 8 million). Simplified invoices are generally excluded, as are some regulated electricity, gas and IATA clearing operations. B2C invoices are not covered, and B2G invoices continue to go through FACe or FACeB2B-type entry points.

Process

ERP creates the invoice in a permitted format → sent through a private platform or the public solution → platform validates and signs it → private platforms send a UBL copy to the public solution → buyer receives it → buyer reports acceptance or rejection and payment

Official Sources

BOE - Real Decreto 238/2026, de 25 de marzo (B2B electronic invoicing) BOE - Orden HAC/1028/2026, de 2 de octubre (public e-Invoicing solution) Agencia Tributaria - Public electronic invoicing solution (news, Oct 2026) Agencia Tributaria - SII information leaflet

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