Prepare for Spain e-invoicing as AEAT updates the draft SPFE ministerial order

The Hague, 14 September 2026 On 10 September the Spanish tax administration AEAT presented an updated draft ministerial order for the Solución Pública de Facturación Electrónica (SPFE), the public e-invoicing solution at the centre of Spain’s B2B mandate. The order sets out the format, transport and validation rules invoices must satisfy. For any company that invoices a customer established in Spain, wherever it sits itself, the requirements are now concrete enough to budget and plan against.

What AEAT published

The public consultation ran from 17 April to 8 May 2026 and the EU notification procedure closed on 6 August 2026. Publication in the Boletín Oficial del Estado (BOE) is still pending, and entry into force is planned for 1 October 2026 subject to it. Test environments follow only afterwards, so nobody can test against a live AEAT endpoint.

The underlying framework is settled: Ley 18/2022 (Crea y Crece) provides the legal basis, and Royal Decree 238/2026 of 25 March 2026, published in the BOE on 31 March 2026, implements it. The order fills in the technical layer.

What is technically new

The headline change concerns format. The SPFE works exclusively with UBL 2.5 aligned to EN 16931, using ebXML transport envelopes. Facturae cannot be submitted to the public solution, though it stays valid between private platforms under Royal Decree 238/2026. Peppol BIS messages in UBL are accepted.

Other changes:

• The bespoke corrective invoice extension is replaced by standard BG-24, carrying correction type, method and corrected amounts.
• New excise duty fields (hydrocarbons, alcohol, tobacco, electricity, coal, plastics, landfill and incineration) plus BG-34 for third-party charges and withholdings.
• Invoices receive an encrypted retrieval reference, the localizador, instead of an authorisation stamp.
• An ApplicationResponse cancellation message allows withdrawal of an invoice for a non-existent transaction, with full traceability.
• Submissions run in batches of 1 to 100 invoices, capped at 5,120 KB.
• The SPFE offers web services plus a free invoicing application, alongside connection with private platforms.

AEAT states explicitly that the SPFE is not a storage or backup service. Retention stays with the business.

Four layers of validation

Every submission passes UBL syntax validation through XSD, semantic EN 16931 validation, Schematron business rules from the 2026 artefacts, and interoperability checks between private platforms and the public solution. It is then admitted with a verification code or rejected with error details, within a four-day correction window. An invoice can be valid XML and still fail a semantic rule.

Architecture and timeline

Spain has chosen a hybrid five-corner model. Private platforms route invoices and lifecycle data between the parties, while a faithful electronic copy goes to the SPFE simultaneously. The public solution is both a mandatory repository and an optional service for smaller businesses.

• 1 August 2027 at the latest: the SPFE is operational.
• 1 October 2027: mandatory above 8 million euro turnover, for issuing, receiving and status reporting.
• 1 October 2028: all remaining businesses and self-employed professionals.
• 1 October 2029: status reporting by individuals and income-attribution entities.

Scope covers domestic B2B transactions where the recipient is a business or professional established in Spain, including the self-employed and micro-enterprises. Simplified invoices, regulated energy companies and B2C are out of scope.

VeriFactu is a different regime

This is the most common mistake. VeriFactu concerns certification of invoicing software and has applied to companies since 1 January 2026 and to the self-employed since 1 July 2026. It is separate from the B2B mandate: being VeriFactu compliant does not make you ready for the SPFE, and the reverse is equally true. See our explainer on Spanish e-invoicing and VeriFactu.

What this means and what to arrange now

Checklist for business owners and finance

1. Establish whether you are in scope. If you sell to a business or professional established in Spain, or have an establishment there, the mandate affects you regardless of the country your own business is registered in.
2. Put your turnover threshold in the calendar. Above 8 million euro your date is 1 October 2027, below it 1 October 2028. An ERP project of nine to twelve months therefore starts in 2026.
3. Clean up your master data. NIF numbers, invoice series and issue date together form the uniqueness key. Poor customer data turns into rejections.
4. Set up the status process. Recipients report commercial acceptance or rejection with a date, and full effective payment with the actual receipt date, within four calendar days excluding weekends and public holidays. Partial acceptance, partial payment and assignment to third parties are optional. This is an AP and AR process question, not an IT question.
5. Arrange your own archive. The SPFE stores nothing for you. Contract six years of archiving with integrity assurance from your provider.
6. Separate VeriFactu and the B2B mandate in your project plan, with distinct owners and criteria.

Checklist for integrators and Peppol Serviceproviders

1. Plan the move to UBL 2.5 aligned to EN 16931. An existing UBL 2.1 mapping does not cover the new excise and BG-34 fields.
2. Replace bespoke corrective invoice extensions with BG-24 before building against the test environment.
3. Build ebXML enveloping and batch logic for 1 to 100 invoices per submission within the 5,120 KB limit.
4. Implement handling of the localizador and the ApplicationResponse cancellation message, including audit trail.
5. Test your platform against Royal Decree 238/2026: ISO/IEC 27001, AS2 or AS4 transport, eIDAS-compliant signing, free interconnection within one month and six years of archiving.
6. Build all four validation layers into your own preflight, so customers do not discover a failing Schematron rule at AEAT. Reflect the four-day correction window in your SLA.
7. Reserve test capacity for the fourth quarter of 2026, since test environments arrive only after BOE publication.

Every national rollout so far, from Italy to France, has shown the same pattern: administrative preparation takes longer than the technical connection. Our French e-invoicing checklist shows how that plays out for suppliers based outside the country itself.

Sources

1. VATupdate, AEAT presents updated draft ministerial order on the public e-invoicing solution (SPFE), 12 September 2026
2. RTC, Spain’s mandatory B2B e-invoicing takes shape: Royal Decree 238/2026 and the draft ministerial order
3. VATupdate, Spain’s AEAT reveals deeper technical controls for the 2027-28 B2B e-invoicing rollout, 27 May 2026
4. BOE, Real Decreto 238/2026, de 25 de marzo (BOE-A-2026-7295)
5. Agencia Tributaria, Facturación electrónica obligatoria, 31 March 2026

Get your provider ready in time

Your choice of Peppol Serviceprovider decides whether UBL 2.5, ebXML and status reporting become a configuration exercise or a build project. On Peppol.nu you can compare providers against your own criteria, free and without obligation.