Spain B2B e-invoicing: Orden HAC/1028/2026 fixes the dates for 2027 and 2028

Madrid, 7 October 2026. Spain B2B e-invoicing now has fixed start dates. On 5 October 2026 the Spanish Official State Gazette (BOE) published Orden HAC/1028/2026, which sets out the technical and functional elements of the public e-invoicing solution of the Spanish Tax Agency (AEAT). The order entered into force on 6 October 2026. This starts the clock: companies with turnover above €8 million must issue invoices to business customers in Spain electronically from 6 October 2027, and all other businesses and self-employed professionals from 6 October 2028.

On 14 September 2026 we covered the updated draft order for the public solution. That draft is now final. For every company that invoices customers in Spain, the dates are now set.

What Orden HAC/1028/2026 regulates

The order (BOE-A-2026-20587, dated 2 October 2026) implements Real Decreto 238/2026 of 25 March 2026, which in turn gives effect to the B2B obligation in the Crea y Crece law (Ley 18/2022). The key points:

• Data model and syntax: e-invoices issued or exchanged through the public solution follow the European semantic data model EN 16931 in UBL syntax.
• Copy to the AEAT: businesses that invoice through a private platform or their own system rather than the public solution must send a faithful copy of each invoice in UBL to the public solution at the moment of issue.
• Invoice status: the recipient reports any rejection of the invoice, the date of full payment and the due date of the payment term.
• Free public solution: access and use are free of charge. Besides system-to-system connections, invoices and status messages can also be entered individually. The solution must be available at least two months before the first obligation applies, so no later than 6 August 2027.

Spain B2B e-invoicing deadlines: 6 October 2027 and 6 October 2028

Real Decreto 238/2026 links the start dates to the entry into force of this order:

• Turnover (volumen de operaciones) above €8 million in the previous calendar year: mandatory from 6 October 2027. During the first twelve months the e-invoice must be accompanied by a PDF that ensures legibility, unless the recipient accepts the original format only.
• All other businesses and self-employed professionals: mandatory from 6 October 2028.
• Individuals and entities under the régimen de atribución de rentas with turnover up to €8 million: reporting invoice status is voluntary until 6 October 2029.

Private platforms, Peppol and the public solution

The Spanish system consists of private invoice exchange platforms and the AEAT public solution. Real Decreto 238/2026 lists four permitted syntaxes: UBL, CII, the EDIFACT invoice message and Facturae. Under Article 7.1, messages in Peppol BIS are also valid insofar as they use UBL syntax. Private platforms must, at a customer’s request, connect free of charge with any other private platform and be able to convert invoices between all permitted formats. Orden HAC/1028/2026 itself does not mention Peppol: it governs the public solution and how private platforms connect to it.

For comparison: in Belgium, structured e-invoicing between VAT-registered businesses has been mandatory since 1 January 2026, via Peppol. In France, all businesses have had to be able to receive e-invoices since 1 September 2026, and large and mid-sized companies issue them through Plateformes Agréées; small and micro-enterprises follow on 1 September 2027. Germany has required receipt since 1 January 2025, with a phased issuing obligation in 2027 and 2028. In the Netherlands, the government has chosen mandatory B2B e-invoicing from 1 July 2030; the legislation is still being prepared. Luxembourg has required e-invoicing to public bodies (B2G) from all suppliers since 18 March 2023, but has no B2B obligation.

What it means and what to do now

Does your company invoice business customers in Spain, or do you have a Spanish entity? Then complete these steps before 6 October 2027 (turnover above €8 million) or 6 October 2028 (all other businesses):

1. Establish whether the obligation applies to you. It applies to businesses that must issue an invoice under the Spanish invoicing rules (Real Decreto 1619/2012) where the customer has its seat, permanent establishment or residence in Spain. If you are established outside Spain, have each invoice flow checked to see whether the Spanish invoicing rules apply.
2. Determine your start date. Compare your turnover for the previous calendar year with the €8 million threshold and plan back from 6 October 2027 or 6 October 2028.
3. Choose your channel. You can use the free AEAT public solution, a private platform, or both. If you choose a private platform, ask whether it sends the UBL copy to the AEAT and connects with other platforms.
4. Check your formats. Can your software create an e-invoice compliant with EN 16931 in UBL, CII, EDIFACT or Facturae? A Peppol BIS invoice in UBL meets the syntax requirement.
5. Set up status reporting. Your accounts payable team must be able to report rejections and payment dates for invoices received; your accounts receivable team must be able to process those messages from customers.
6. Plan the PDF transition period. If you are in the first group, agree with your customers whether they want an accompanying PDF during the first twelve months.
7. Do not forget purchasing. A Spanish entity will receive e-invoices from Spanish suppliers from the same dates and must report their status.

Sources

1. BOE: Orden HAC/1028/2026, de 2 de octubre, por la que se regula la solución pública de facturación electrónica (BOE-A-2026-20587, 5 October 2026)
2. BOE: Real Decreto 238/2026, de 25 de marzo, sistema de facturación electrónica obligatoria entre empresarios y profesionales (BOE-A-2026-7295)
3. BOE: Ley 18/2022, de 28 de septiembre, de creación y crecimiento de empresas (BOE-A-2022-15818)
4. Agencia Tributaria: Manual IVA 2026, factura electrónica obligatoria
5. Iberley: Publicada en el BOE la orden que marca el inicio del plazo para la obligatoriedad de la factura electrónica B2B
6. Pressdigital: Hacienda regula la solución pública de factura electrónica (5 October 2026)
7. FPS Finance (Belgium): From when is e-invoicing mandatory?
8. Ministry of the Economy (France): Tout savoir sur la facturation électronique pour les entreprises
9. Federal Ministry of Finance (Germany): Fragen und Antworten zur E-Rechnung
10. Government of the Netherlands: Kabinet kiest voor invoering e-facturatie en rapportage voor bedrijven (11 September 2026)
11. Ministry for Digitalisation (Luxembourg): La facturation électronique au Luxembourg

Which platforms and Peppol Service Providers support invoicing to Spain? In the Peppol.now comparison tool you can compare solutions by country, format and integration, so you can choose your approach to Spain B2B e-invoicing well before 6 October 2027.