Spain is progressing toward implementation of its mandatory B2B e-invoicing regime following the publication of Royal Decree 238/2026. The next critical step is the Ministerial Order establishing the technical rules for the Public Electronic Invoicing Solution (SPFE), which AEAT’s 2026 planning indicates is intended to enter into force on 1 October 2026.
The date is not yet final, as the Ministerial Order still needs to be published. AEAT is continuing its technical work, including a 10 September 2026 session covering updates to the draft Order and the SPFE.
Timeline: when Spain's B2B e-invoicing mandate takes effect
If the Ministerial Order enters into force on 1 October 2026, mandatory B2B e-invoicing would apply from 1 October 2027 to businesses with annual turnover above €8 million and from 1 October 2028 to the remaining businesses and professionals.
These implementation dates therefore remain dependent on the final publication and entry into force of the Ministerial Order.
What the Ministerial Order means for businesses
The planned Ministerial Order will provide the technical detail businesses and service providers need to prepare for Spain’s B2B e-invoicing mandate. Its publication will also start the countdown toward mandatory adoption for the two groups of taxpayers covered by the legislation.
Key developments in Spain's SPFE rollout
Key developments include:
- 1 October 2026 is currently the target date for the Ministerial Order governing the SPFE to enter into force.
- Businesses with annual turnover above €8 million would be required to comply from 1 October 2027, if the planned timetable is maintained.
- Remaining businesses and professionals would follow from 1 October 2028.
- AEAT continues to develop the technical framework for the SPFE and update the draft Ministerial Order.
- The Spanish Senate has separately called for B2B e-invoicing, VERI*FACTU and SII to converge toward a single transaction-reporting model aligned with ViDA.
The Senate initiative does not change the current B2B e-invoicing mandate or its expected timetable. For businesses preparing for the Spanish requirements, the immediate milestone remains the publication of the Ministerial Order.
How to prepare for the €8 million turnover threshold
Companies potentially within scope, particularly those exceeding the €8 million turnover threshold, should continue assessing their invoicing processes, systems and integration requirements so they are positioned to implement the final technical specifications once they are formally adopted.
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