Spain announced it for years — now the clock is running. On 5 October 2026 the official gazette BOE published ministerial order HAC/1028/2026, in force since 6 October. It starts the deadlines for mandatory B2B e-invoicing: from 6 October 2027 for large businesses, from 6 October 2028 for everyone else. What the order regulates, which formats are allowed and what it means for businesses in Germany.
As of 16 October 2026. The B2B dates are fixed. For Verifactu, Spain's second project, a further postponement has been announced but not adopted — details below.
The deadlines
The Crea y Crece act (Ley 18/2022) requires electronic invoices between businesses, and Royal Decree 238/2026 of 25 March 2026 sets out the details. Both had a catch: the deadlines would only start once the technical ministerial order was in force. That order is now here.
| From | Who is affected |
|---|---|
| 6 October 2027 | businesses and self-employed with more than €8 million turnover (12 months after the order took effect) |
| 6 October 2028 | all other businesses and self-employed (24 months after) |
Excluded are, among others, simplified invoices (till receipts) and invoices to consumers — B2C is not covered by this obligation.
What the order regulates
HAC/1028/2026 mainly describes the public solution of the Spanish tax agency AEAT: a free platform aimed primarily at small businesses and the self-employed. Invoices can be issued there through a web form or an interface. The platform must be available at least two months before the first deadline.
Anyone using a private platform instead may continue to do so. The platform then sends a faithful copy of each invoice to the public solution — so the tax agency sees every B2B invoice, whichever route it takes. Private platforms must be interconnected and able to convert between the permitted formats.
New for many: the recipient reports back through the system whether it accepts or rejects the invoice and when it paid. Spain wants to make late payment visible — that was the original aim of the act.
Which formats are allowed
The invoice must be a structured message under the European standard EN 16931, in one of four syntaxes:
- UBL — the syntax of the public solution and of the copies sent to the AEAT,
- CII (UN/CEFACT Cross Industry Invoice) — the same syntax as in the XML part of ZUGFeRD and Factur-X,
- EDIFACT,
- Facturae — the Spanish format long used in the public sector.
A PDF on its own is not enough, not even by email. For the public solution the order also sets a list of mandatory fields that go beyond the standard.
Not to be confused: Verifactu
Spain is also running Verifactu. It is not an e-invoicing mandate but a requirement for the invoicing software itself: records must be tamper-evident and data goes to the tax agency. Under Real Decreto-ley 15/2025 the applicable dates are 1 January 2027 for corporate income tax payers and 1 July 2027 for everyone else.
In October 2026 the tax administration announced it would postpone Verifactu to October 2028, aligning it with B2B e-invoicing. This postponement has not yet been published in the official gazette. Until it is, the 2027 dates apply.
What this means for businesses in Germany
- Your Spanish customers must receive electronic invoices and report payment status from 2027 or 2028. The obligation is tied to the recipient being established in Spain or having an establishment there.
- Whether a supplier without an establishment in Spain has to invoice through the Spanish system itself is not answered consistently in the commentary so far. Clarify it with your Spanish customer or a Spanish tax adviser before the deadline draws near.
- You have an establishment in Spain: then the deadlines apply to it — with the €8 million threshold.
- Your invoice data under EN 16931 is a good starting point: CII is permitted, and a dataset that meets the standard can be converted into the other syntaxes. How the countries differ in detail is covered in E-invoicing mandates in Europe.
Frequently asked questions
When does Spain's B2B e-invoicing mandate apply?
From 6 October 2027 for businesses with more than €8 million turnover, from 6 October 2028 for everyone else. The deadlines have been running since order HAC/1028/2026 took effect on 6 October 2026.
Can I send a ZUGFeRD invoice to Spain?
The XML part of ZUGFeRD in the EN 16931 profile is CII, and CII is one of the permitted syntaxes. In Spain, however, the invoice travels through a platform, not as a PDF by email; whether and in what form a platform accepts the file is up to the platform. Ask your customer which route they receive through.
Has Verifactu been postponed?
Announced, yes; adopted, no. Until the change appears in the official gazette, 1 January and 1 July 2027 apply.
Can E-Rechnung Pro submit invoices to the Spanish system?
No. We create ZUGFeRD and Factur-X and validate ZUGFeRD, Factur-X and XRechnung. We are not connected to the AEAT's public solution or to Spanish platforms.
In short
- Since 6 October 2026 the deadlines for B2B e-invoicing have been running in Spain.
- Key dates: 6 October 2027 (above €8 million turnover) and 6 October 2028 (everyone else).
- UBL, CII, EDIFACT and Facturae under EN 16931 are permitted; a copy of every invoice ends up with the tax agency.
- Verifactu is a separate project; the announced postponement to 2028 has not been adopted yet.
You invoice within the EU? An invoice under EN 16931 is the common ground everywhere — create an e-invoice, free until 31.12.2026.
E-Rechnung Pro creates and validates documents against EN 16931:2017 — the version ZUGFeRD 2.x and Factur-X are built on today. We are following the EN 16931-1:2026 revision and will support it as the formats adopt it.