Regulatory updates - Spain

AEAT has published two documents, giving the clearest picture yet of how the SPFE will operate. Document 1 covers what it does; Document 2 covers how to connect to it.

Document 1 (Ministerial Order Project for the Public Electronic Invoicing Solution), Functional, confirms the following aspects:

• Hybrid model: When the electronic invoice issuance and interconnection are not performed via the SPFE, private platforms must deposit a faithful copy (copia fiel) in the SPFE simultaneously with issuance, flagged via CopyIndicator;
• Each invoice carries a unique code (NIF + series-number + issue date) enabling automatic deduplication;
• Mandatory lifecycle statuses: rejection or acceptance (silence equals acceptance), full payment date, and due date;
• Platforms must aggregate traffic, hold formal Power of Attorney (SP. apoderamiento) per client, and retrieve invoices automatically; thin pass-through models are non-compliant.

Document 2 (Public Electronic Invoicing Solution (SPFE)), Technical aspects. The following technical baseline is defined:

• Syntax: UBL 2.5 exclusively, aligned to EN 16931:2026;
• Two-layer validation: XSD for syntax, Schematron for business rules, must be embedded by senders; no public online validator;
• Connectivity via synchronous web services with certificate-based authentication;
• Representation asymmetry: sending allows Power of Attorney (SP. apoderamiento) or social collaborator; retrieving requires Power of Attorney (SP. apoderamiento) only, automated retrieval without registered representation is blocked.

What is next

Once the Ministerial Order is published in the BOE (expected October 1, 2026), transitional periods begin, the sandbox opens, and developer portal documentation, XSD schemas, Schematrons, WSDLs, message examples, follows before go-live.

Large businesses face mandatory compliance in October 2027. The technical picture is defined enough to act now. Prioritise UBL 2.5 readiness, Power of Attorney (SP. apoderamiento) onboarding design, and embedding validation logic. October 2027 is manageable for those who start in October 2026.

The country has taken another concrete step toward rolling out mandatory B2B electronic invoicing. The Ministry of Finance has published a draft Ministerial Order regulating the public electronic invoicing platform under the Crea y Crece framework, launching a formal public consultation phase. 

This draft Order is a key operational milestone, as it sets out how the public e-invoicing solution managed by the Spanish Tax Agency (AEAT) is expected to function in practice. 

What the draft Order covers 

The draft Ministerial Order focuses on the operational and technical rules for Spain's public e-invoicing solution, including: 

• How businesses can issue and receive electronic invoices via the AEAT platform; 

• How invoices and data must be transmitted to the public solution when private e-invoicing platforms are used; 

• Communication of mandatory invoice statuses, including acceptance, rejection, and effective payment; 

• Technical interoperability between the public solution and private platforms; 

• Identification, authentication, and representation requirements for users of the platform; 

• Use of structured formats aligned with European standards. 

Once the Ministerial Order is formally approved and published, it will activate the phased enforcement timeline for B2B electronic invoicing in Spain. Under the Crea y Crece framework: 

• Large companies will be required to comply first; 

• Smaller businesses and professionals will follow later, after an additional transition period. 

The exact enforcement dates will depend on the final publication and entry-into-force date of the Order. 

Consultation Details 

The consultation phase represents the last opportunity for companies, software providers, and other stakeholders to provide feedback on how the public e-invoicing platform will operate. 

Stakeholders are invited to submit comments by May 8, 2026. 

If adopted as drafted, the Order is expected to take effect on October 1st 2026, with a 12-month notice for the first group and 24 months for other taxpayers. This date may still change.

At this stage, the draft has no binding legal effect. The final content may still change following the consultation. 

On March 24, 2026, the Council of Ministers approved a Royal Decree activating the B2B electronic invoicing obligation established under Law 18/2022, commonly referred to as Crea y Crece (Create and Grow). This marks the most significant concrete step forward for the initiative since the law was passed in 2022.

The Royal Decree establishes mandatory B2B electronic invoicing between companies, as well as between companies and professionals, including sole traders acting in a professional capacity. It defines electronic invoices as structured, machine-readable files, effectively ending the use of PDFs, Excel spreadsheets, and paper invoices. The decree also introduces a mandatory reporting requirement for invoice status, covering issuance, acceptance or rejection, and the actual payment date. The measure is explicitly linked to reducing commercial late payments.

What has not yet entered into force

Although the Royal Decree has been approved, the obligation does not take effect immediately. Enforcement depends on the publication of a Ministerial Order.

The Ministerial Order will:

• Regulate the public B2B e-invoicing platform;
• Define final technical rules and interoperability requirements; and
• Start the legal countdown for enforcement.

What is expected next

The Government has confirmed that the Ministerial Order on the public e-invoicing platform is expected before July 1, 2026. It will be issued by the Ministry of Finance, although the Ministry of Economy holds the policy lead. Once published, the Order will represent the true legal starting point for Crea y Crece enforcement, and implementation deadlines will begin to count.

Planned rollout

The rollout will be phased based on company size:

• Companies with annual turnover above 8 million EUR: obligation begins one year after the Ministerial Order is published;
• All other companies and professionals: obligation begins two years after the Ministerial Order is published.

As an example: if the Order is published in the first half of 2026, this implies large companies would need to comply from 2027, and small and medium-sized enterprises (SMEs) and sole traders from 2028.

Additional provisions

The Royal Decree also confirms the following:

• A free, public B2B e-invoicing platform will be operated by the Spanish Tax Administration Agency (AEAT: Agencia Estatal de Administración Tributaria);
• Use of the public platform is optional;
• Private platforms remain permitted but must be interoperable with the public system; and
• Copies of invoices and invoice status data must be shared with the public system.

Crea y Crece and Veri*factu are separate measures

The Government has clarified that, while the B2B electronic invoicing decree and Veri*factu are being processed in parallel, they are different and independent measures. Businesses should ensure they understand the distinct obligations and timelines associated with each.