Spain defines public e-invoicing model in draft Order
Draft Order clarifies format, reporting and platform setup ahead of 2026 start
Spain is moving into the next phase of its e-invoicing rollout. With the publication of a draft Ministerial Order, the Spanish Tax Authority, AEAT, provides concrete details on how the public e-invoicing solution will operate. At the same time, it invites businesses and service providers to respond before the rules are finalised.
On 17 April 2026, AEAT opened a public consultation on the draft Order that defines the technical and functional setup of its public e-invoicing platform. The consultation runs until 8 May 2026. The final Order is expected to enter into force on 1 October 2026, which will formally start the compliance timelines under Ley 18/2022 and Royal Decree 238/2026. This step builds on earlier developments, including the confirmed Spanish e-invoicing mandate and the updated implementation timeline.
What the draft Order makes clear
The draft focuses on how invoices are created, exchanged and reported within the Spanish model. A number of choices stand out and show a clear direction towards standardisation and control.
All invoices exchanged via the public solution must follow EN 16931 using UBL syntax. This also applies to the “copia fiel” that private platforms must send to AEAT. This approach aligns with earlier decisions to bring Spain in line with European standards, as explained in this update on EU alignment.
At the same time, Spain keeps a dual model. Companies can exchange invoices via the public platform or through accredited private platforms. However, private platforms must always send a faithful copy to AEAT. This ensures that the tax authority has full visibility, regardless of the channel used.
Each invoice must also include a unique identifier. This identifier is based on the supplier’s NIF, invoice number and series, and the issue date. This creates a consistent reference across systems and reporting flows.
Payment status reporting becomes operational
One of the more impactful elements is the requirement around payment status updates. This moves the model beyond invoice exchange into ongoing process monitoring.
Invoice recipients must report acceptance or rejection, as well as full payment details, within four calendar days. This includes both payment date and due date. All status messages must follow UBL standards as defined in the annex of the draft Order. For issuers, reporting on collection or non-payment remains optional.
This introduces a near real-time view on the commercial lifecycle of invoices. For many organisations, this will affect accounts payable processes, dispute handling and internal controls. It also connects to earlier reporting developments, including SII and VeriFactu, as outlined in this update on reporting changes.
Integration and access requirements
The draft clarifies how systems are expected to connect and interact with the public solution.
Private platforms that use the public solution as a hub must ensure automatic retrieval of incoming invoices and make them immediately available to their clients. This removes manual steps and enforces a more integrated process.
Access to the platform requires qualified electronic certificates. The Cl@ve system can be used for web-based interactions. AEAT also commits to making the public solution available at least two months before the first compliance deadline. This creates a defined, but limited, preparation window.
What is still missing
Not all elements are available yet, and this has a direct impact on preparation.
The detailed technical specifications, including data schemas and API contracts, are not part of the draft Order. These will be published separately via the AEAT electronic portal. Until then, software providers and IT teams cannot complete full integrations, which means that part of the implementation timeline remains uncertain.
Key dates to work towards
The draft confirms a phased rollout with clear milestones that companies need to track closely.
- 1 October 2026: expected entry into force of the Ministerial Order, starting all compliance timelines
- Around August 2027: public solution becomes available, at least two months before the first deadline
- 1 October 2027: private platforms must comply with interoperability and “copia fiel” requirements
- 1 October 2027: large companies, with turnover above €8 million, must comply with e-invoicing and status reporting, including a temporary PDF obligation
- 1 October 2028: all other businesses must comply
- 1 October 2029: status reporting obligation is deferred for smaller self-employed entities
These milestones reflect the phased approach Spain has taken so far, including earlier decisions to adjust timing and sequencing of the rollout.
What this means for businesses
This draft confirms that Spain is not only mandating e-invoicing, but also reshaping how invoice data is managed and monitored.
Companies need to prepare for standardised invoice formats, integration between systems and platforms, and new processes for tracking and reporting invoice status within strict timelines. This will require closer alignment between finance, IT and compliance teams.
For organisations already using private platforms, the requirement to send a “copia fiel” to AEAT adds an additional layer that must be embedded in existing processes.
Why the consultation matters
The consultation period is a moment where impact can still be influenced.
Businesses and service providers can raise practical concerns around implementation timelines, payment status workflows and message structures before the Order is finalised. Submissions are open until 8 May 2026, after which the framework will move towards enforcement.
Changes companies need to implement
Companies operating in Spain should now move from awareness to preparation. This means assessing the current invoicing landscape, defining how to connect to public or private platforms, and understanding the operational impact of payment status reporting.
Engaging with technology providers early is essential. With technical specifications still pending, organisations need to stay flexible and ready to adapt. The direction is clear. The focus now shifts to execution.
