During the webinar, the AEAT (Agencia Estatal de Administración Tributaria) provided additional information on the Public Electronic Invoicing Solution (“Solución Pública de Facturación Electrónica” – SPFE), ahead of the publication of the final Ministerial Order.
These new clarifications follow several important regulatory and technical developments over the past months:
- The publication of Royal Decree 238/2026, which established the main principles of the future B2B e-invoicing framework and provided initial clarifications on the future mandate
- The publication of the draft Ministerial Order and initial technical guidance regarding the SPFE
Also, more recently, the Spanish Senate approved a non-binding motion [↗︎] calling on the Government to progressively align and integrate VERI*FACTU, SII and mandatory B2B e-invoicing into a more unified transaction reporting framework compatible with the EU’s VAT in the Digital Age (ViDA) requirements.
While the motion does not modify the current implementation timelines and is not legally binding, it highlights the broader objective of ensuring greater consistency between Spain’s different digital invoicing and VAT reporting frameworks ahead of the EU Digital Reporting Requirements.
Key topics presented during the webinar
Implementation timeline
The Spanish authorities reiterated the expected implementation calendar, beginning with the publication and entry into force of the Ministerial Order targeted for October 2026.
While 1 October 2026 remains the expected date according to the official written documentation, in line with previous communications, the AEAT indicated during the webinar that the Ministerial Order is expected to enter into force during October 2026, acknowledging that its publication may face a slight delay and therefore not occur exactly on 1 October.
Hybrid model
Reminder that Spain will operate a hybrid e-Invoicing model, combining private e-Invoicing platforms and the Public Electronic Invoicing Solution managed by the AEAT.
Format & standard of the SPFE
The webinar primarily focused on the technical specifications of the SPFE, for which the AEAT confirmed the use of the new UBL 2.5 standard, aligned with the EN 16931 semantic model.
While the e-invoicing formats and specifications applicable to exchanges between private platforms were not specifically addressed during the webinar, which primarily focused on the technical specifications of the SPFE, further clarification is still expected regarding the versions and semantic specifications applicable to such exchanges, notably in light of the recently published EN 16931:2026 and UBL 2.5, and taking into account the format requirements applicable to the “faithful copy”.
“Faithful Copy” (Copia Fiel)
The webinar provided an important technical clarification, with the AEAT indicating that the SPFE will rely on UBL 2.5, the latest version of the Universal Business Language standard approved by OASIS in August 2026.
This may therefore require private e-invoicing platforms to transform or map invoices exchanged under other syntaxes, versions or specifications into the format required by the SPFE. This will be particularly relevant where the original invoice is exchanged using existing specifications such as Peppol BIS Billing 3.0, currently based on UBL 2.1 and EN 16931:2017.
Invoice lifecycle reporting
The SPFE will support the reporting and management of invoice lifecycle events, including acceptance/rejection and payment-related statuses. The webinar provided additional technical information on the communication of these events through the public solution.
SPFE technical services
The webinar also provided further details on the submission, consultation and retrieval of invoices, as well as the validation controls performed by the SPFE, including UBL, EN 16931 and AEAT-specific validation rules.
Next steps
The next expected steps towards implementation are therefore the publication of the final Ministerial Order, followed by the release of the detailed technical specifications and testing environment, expected from October 2026.
These developments should provide further clarity on the practical and technical implementation of the future Spanish B2B e-Invoicing framework and allow businesses and e-Invoicing service providers to progressively prepare their systems and processes for the upcoming mandate.
