Spain confirms B2B e-invoicing mandate with Order HAC/1028/2026
Spain has published Order HAC/1028/2026, setting out the technical and functional elements of the country's public electronic invoicing solution. Its publication is a key milestone because it starts the countdown for Spain's mandatory B2B e-invoicing regime and gives businesses clear implementation dates.
Timeline: Spain's B2B e-invoicing mandate dates for 2027 and 2028
The Order was published on 5 October 2026 and enters into force on 6 October 2026. The mandate will then apply in two phases:
- From 6 October 2027: businesses and professionals whose volume of operations exceeded €8 million in the preceding calendar year.
- From 6 October 2028: all remaining businesses and professionals.
What Order HAC/1028/2026 means for businesses
The mandate requires businesses and professionals to issue and receive electronic invoices for B2B transactions where the recipient has its business establishment, a permanent establishment, or its domicile or habitual residence in Spain.
How Spain's public and private e-invoicing solutions work together
The Spanish system combines private e-invoicing platforms with a public solution operated by the tax authority, AEAT.
Where the public solution is not used for issuance or interconnection, a faithful copy of each invoice in UBL must be sent to the public solution at the time of issuance. Recipients must also report to the public solution either the rejection of an invoice or, for paid invoices, the full payment and the payment due date.
Key technical elements of the public electronic invoicing solution
Order HAC/1028/2026 defines key technical elements of the public infrastructure. These include UBL based on EN 16931, faithful copies, unique invoice coding, and status and payment messages. Additional technical specifications, conditions and volumetry will be provided through the AEAT electronic office.
For businesses operating in Spain, the publication means preparations can now be planned against fixed 2027 and 2028 compliance dates, rather than a timetable dependent on a future technical order.
Partner with Fonoa for Spain e-invoicing compliance
Navigating Spain's B2B e-invoicing mandate alongside other evolving requirements across the EU can be complex. Fonoa helps businesses manage e-invoicing, tax determination, and reporting obligations on one platform, so you can stay compliant as regulations like Spain's move from legislation to implementation. Get in touch to see how Fonoa can support your e-invoicing readiness.
