Spain: final e-invoicing deadlines confirmed

What is changing?

Spain has confirmed the final timeline for mandatory B2B e-invoicing.

Order HAC/1028/2026 has been published and confirms the operational rules for AEAT’s public e-invoicing solution. The deadlines are now fixed:

– 6 October 2027 for businesses and professionals with turnover above EUR 8 million.
– 6 October 2028 for the remaining businesses and professionals in scope.

Spain will allow the use of private platforms, AEAT’s public solution, or both. When invoices are exchanged outside the public solution, a faithful electronic copy must also be submitted to AEAT in UBL format.

Why it matters

This is a reason to contact customers with Spanish entities, customers or invoice flows and check whether they are already preparing for implementation.

Spain’s model goes beyond sending and receiving structured invoices. It also includes invoice lifecycle and payment status reporting, including payment due dates, full payment dates, rejection, collection and non-payment.

Start with these customer questions:

– Which Spanish entities and invoice flows are in scope?
– Does the customer fall under the 2027 or 2028 deadline?
– Will invoices be exchanged through private platforms, AEAT’s public solution, or both?
– Can the ERP create the required structured invoice data?
– Can invoice lifecycle and payment status information be captured reliably?
– Who manages validation errors, rejection flows and status updates?

One detail to check carefully

Spain requires more than format readiness. Customers need to understand how invoice status, payment information and correction flows will be managed across ERP, AR, AP and reporting processes.

Customers should confirm exact scope, platform approach and reporting obligations with their local finance or tax team.

Talking point

“Spain has now confirmed the final B2B e-invoicing deadlines for 2027 and 2028. Shall we check whether your Spanish invoice flows are ready, from platform choice and UBL requirements to lifecycle reporting and ERP data?”

What should partners do next?

Contact customers with Spanish entities or transaction flows and arrange a readiness review with finance, tax and IT. Focus on scope, deadlines, platform strategy, UBL faithful copy, invoice lifecycle reporting and how Routty can support Spain within a broader European e-invoicing roadmap.