The long-awaited Ministerial Order, a critical step towards implementation as it triggers the countdown to the B2B e-invoicing obligations, has now been officially published, following the publication of Royal Decree 238/2026 in March and the technical webinar held by the Spanish authorities in September.
Order HAC/1028/2026, published in the Official State Gazette (BOE) [↗︎] on October 5, 2026, enters into force on October 6, 2026, providing the detailed technical and operational framework required for implementation, without changing the timeline already established by Royal Decree 238/2026.
Implementation timeline confirmed
The Spanish B2B e-invoicing obligations will apply progressively as follows:
- October 6, 2027 – Businesses and professionals with annual turnover exceeding 8 M€ will be required to issue and receive electronic invoices, as well as comply with the applicable invoice status and payment reporting obligations.
- October 6, 2028 – Other businesses and professionals will be required to issue and receive electronic invoices under the new framework.
- October 6, 2029 – The invoice status and payment reporting obligations will become applicable to the categories benefiting from the additional transitional period.
Additionally, during the first year of the mandate, businesses with turnover above 8 M€ must also provide a human-readable copy (e.g. PDF) where the recipient is not yet able or required to receive e-invoices.
At this stage, no grace period has been announced, although this should be monitored given the broader European trend towards such “soft landings” around go-live.
Transmission channels and formats
The Ministerial Order confirms the possibility to exchange e-invoices either through Spain’s tax authority (AEAT) public e-invoicing solution or through private e-invoicing platforms.
It also provides in Annex I the detailed invoice data model applicable to the public solution, based on the EN 16931 semantic model. While it does not explicitly refer to UBL 2.5, the AEAT indicated during its September technical webinar that UBL 2.5 would be used as the syntax for the public solution.
The Order also specifies that, where invoices are exchanged through private e-invoicing platforms, a faithful copy (“copia fiel”) must be transmitted to the AEAT public solution in compliance with the format and data model defined in Annex I (Article 4).
Invoice lifecycle reporting further specified
The Order further specifies the invoice lifecycle and payment reporting framework established by Royal Decree 238/2026. In particular, invoices are presumed accepted in the absence of rejection or a subsequent corrective invoice, but no specific timeframe is established for rejection or for the invoice to be considered tacitly accepted.
Suppliers may also voluntarily report collection, non-payment or discrepancies with the payment date reported by the buyer (Article 7), while effective payment information must be reported by the buyer within four days following payment.
Annex II now provides the detailed data model and structured messages for lifecycle and payment reporting, while Article 8 defines their transmission, validation and correction procedures.
Other technical and operational provisions
Finally, the Ministerial Order covers additional operational topics:
- The unique invoice identification code, based on the issuer’s NIF, invoice series and number, and issue date (Article 6)
- The invoice recovery by private platforms and recipients (Article 9)
- The consultation and download services (Article 10)
- The access, authentication and representation requirements (Article 11).
It also sets out specific procedures applicable in case of technical unavailability of the public solution.
Veri*Factu timeline expected to be postponed
Separately, the Spanish Ministry of Finance announced on October 5, 2026 [↗︎] its intention to postpone the remaining Veri*Factu obligations until October 2028, with the specific objective of aligning their implementation with the B2B e-invoicing deadline applicable to businesses and professionals with annual turnover not exceeding EUR 8 million.
This postponement still requires the corresponding regulatory amendment to be formally adopted.
