Mandatory B2B e-invoicing in Spain starting in October 2027
AEAT Schedule and Requirements
The countdown to mandatory e-invoicing in Spain has already begun. On October 6, 2026, Regulation Orden HAC/1028/2026, published in the Spanish Official Gazette (Boletín Oficial del Estado, BOE), entered into force. The regulation sets out the technical and functional rules for the AEAT’s (Agencia Estatal de Administración Tributaria, or State Tax Administration Agency) public e-invoicing platform. Mandatory B2B e-invoicing in Spain is also regulated by the Ley Crea y Crece and Royal Decree 238/2026. For companies with Spanish subsidiaries or branches, this is a signal that it is time to plan the implementation of e-invoicing in their ERP system.
The countdown to mandatory e-invoicing in Spain has already begun. On October 6, 2026, Regulation Orden HAC/1028/2026, published in the Spanish Official Gazette (Boletín Oficial del Estado, BOE), entered into force. The regulation sets out the technical and functional rules for the AEAT’s (Agencia Estatal de Administración Tributaria, or State Tax Administration Agency) public e-invoicing platform. Mandatory B2B e-invoicing in Spain is also regulated by the Ley Crea y Crece and Royal Decree 238/2026. For companies with Spanish subsidiaries or branches, this is a signal that it is time to plan the implementation of e-invoicing in their ERP system.
When will e-invoicing become mandatory in Spain? Timeline for 2027–2029
- October 6, 2027 The B2B e-invoicing requirement will apply to companies with a turnover exceeding 8 million euros. Starting on that date, they must issue, send, and receive e-invoices, as well as report the status of invoices and payments.
- October 6, 2028 The B2B e-invoicing requirement will extend to other companies and business owners.
- October 6, 2029 The requirement to report the status of invoices and payments will apply to business owners who are individuals.
How does the Spanish e-invoicing system work? The UBL format and the AEAT platform
- The EN 16931 format in UBL syntax. EN 16931 is a European standard that specifies the data contained in an e-invoice. UBL is the XML file format in which this data is stored.
- A copy of the invoice on the public platform. A company that uses a private e-invoicing platform simultaneously sends a copy of each invoice to the AEAT platform.
- Status and Payment Reporting. The recipient reports the rejection of the invoice and the date of its full payment, which allows the administration to monitor timely payments between companies.
E-invoicing in Spain and SAP. What needs the adaptation?
Spanish companies using SAP must be prepared to send e-invoices in UBL format directly from the system and to report information to the AEAT regarding the payment or rejection of purchase invoices. The data required for these messages is generated during the invoice payment and approval processes, so these are the processes that need to be adapted within the system.
