Publication of the Ministerial Order on B2B Electronic Invoicing

Publication of the Ministerial Order on B2B Electronic Invoicing

On 5 October 2026, Ministerial Order HAC/1028/2026, dated 2 October, was published in the Spanish Official Gazette (BOE), completing the regulatory framework for mandatory electronic invoicing between businesses and professionals in Spain established by Law 18/2022 (the “Crea y Crece” Law) and Royal Decree 238/2026.

The publication of the Ministerial Order is a particularly important milestone, as it completes the regulatory framework required to start the implementation timetable for mandatory B2B e-invoicing.

The Order enters into force on 6 October 2026. This date therefore represents the “kick-off” from which the implementation periods established by the Royal Decree will start to run.

Accordingly, the implementation timetable is now as follows:

• Businesses and professionals with annual turnover exceeding EUR 8 million: mandatory application from 6 October 2027.

• All other businesses and professionals: mandatory application from 6 October 2028.

The Spanish Tax Agency’s public e-invoicing solution must be available at least two months before the first effective application date.

What does the new e-invoicing system involve?

Electronic invoicing under the new rules should not be understood simply as replacing a paper invoice with a PDF. The new system introduces a structured and automated exchange of information between businesses, providing traceability throughout the invoice lifecycle, from issuance and receipt through certain invoice statuses and ultimately payment.

The main features of the new model include:

• Invoices must be issued in structured, machine-readable electronic formats in accordance with the European EN16931 semantic model.

• The Spanish Tax Agency’s public solution will use UBL as its reference syntax.

• Businesses will be able to use either the public solution or private e-invoicing platforms. Private platforms will be required to ensure interoperability and submit a faithful copy of invoices to the public solution in accordance with the applicable rules.

• The system will allow certain invoice statuses to be reported, including acceptance or rejection, together with information on effective payment.

• A unique invoice identifier will link the invoice to its subsequent statuses and payment information throughout its lifecycle.

The final Order also provides additional clarification compared with the previous draft, particularly regarding access to and downloading of invoices, invoice statuses and payment information, the treatment of faithful copies rejected by the public solution, and the rules applicable in the event of technical incidents.

What should businesses do now?

Although businesses will have a 12- or 24-month adaptation period depending on their turnover, publication of the Ministerial Order marks the effective start of the implementation project.

Over the coming months, businesses should review their current invoicing processes, ERP and accounting systems, e-invoicing platforms, and treasury and payment processes in order to identify the changes required to comply with the new framework.

VeriFactu: an unexpected change to the implementation timeline

In parallel, the Spanish Ministry of Finance has today announced its decision to postpone VeriFactu until October 2028, aligning its timeline with e-invoicing for businesses and professionals with annual turnover of up to EUR 8 million. The change, unexpected at this stage of the implementation process, follows the approach proposed by AEDAF to coordinate VeriFactu, e-invoicing, SII and the future European ViDA framework. Although this represents a further postponement, it may ultimately prove positive if it avoids successive system changes and allows for a more coordinated and efficient implementation. The new timeline will still need to be formally implemented through the corresponding regulatory amendment.

Mandatory B2B e-invoicing should also be distinguished from VERI*FACTU. They are separate regulatory requirements, although both affect invoicing systems and should be considered together when designing future processes.