Spain B2B e-invoicing now has firm dates. Order HAC/1028/2026 was published in the Official State Gazette (BOE) on 5 October 2026 and took effect on 6 October 2026, which starts the calendar set by Royal Decree 238/2026. Businesses whose volume of operations exceeded €8 million in the previous calendar year go first, on 6 October 2027. All other businesses and professionals follow on 6 October 2028.
The dates themselves have been covered widely. What follows is the planning view: when the platform of the Spanish tax agency (Agencia Tributaria, AEAT) arrives, what is worth having ready before it, and how to sequence the twelve months to 6 October 2027.
TL;DR
Under Royal Decree 238/2026 and Order HAC/1028/2026, Spain's B2B e-invoicing mandate starts on 6 October 2027 for businesses whose volume of operations exceeded €8 million in the previous calendar year, and on 6 October 2028 for everyone else. AEAT's free public platform has to be available at least two months before the first date, so by 6 August 2027 at the latest, and testing against it can only start once it is live. Acceptance, rejection and payment statuses will have to be reported within four days, excluding Saturdays, Sundays and national public holidays. Self-employed individuals and income-attribution entities in the second wave must report statuses from 6 October 2029; until then it is voluntary.
When will AEAT's public e-invoicing platform be available?
Under Order HAC/1028/2026, AEAT must make the public solution available at least two months before the first application date, 6 October 2027. That makes 6 August 2027 the latest it can arrive, and it may launch sooner. Testing against it can only start once it is live, so plan for that window to open by that date.
The window covers connection, authentication, invoice validation and status messages, and any earlier launch is a bonus. Work that does not depend on the public platform is best completed before 6 August 2027, so the window stays free for testing.
How to plan backwards from 6 October 2027
Working backwards from 6 October 2027, the sequence is short: confirm which wave your Spanish entities fall into, run a first API test, agree PDF handling with each partner, and keep the period from 6 August 2027 free for testing against AEAT's platform. Bold rows in the table are set by law.
The rest is a suggested sequence rather than a requirement, so move it to fit your release calendar. Dates and conditions come from Royal Decree 238/2026 and AEAT's information note on the decree.
| When | What is ready by then |
|---|---|
| Now / Q4 2026 | Confirm which wave your Spanish entities fall into and what it means for your setup |
| H1 2027 | Read your e-invoicing provider's documentation and run a first test in its sandbox, ahead of AEAT's platform going live |
| H1 2027 | Agree with each customer and supplier whether they expressly accept the structured invoice without a PDF copy |
| 6 Aug 2027 at the latest | AEAT's public solution has to be available |
| Before go-live | Run a final end-to-end check with your technical team and any provider involved to make sure everything works as expected |
| 6 Oct 2027 | First-wave businesses must issue and receive structured invoices and report statuses within four days, excluding Saturdays, Sundays and national public holidays |
| Oct 2027 – Oct 2028 | First-wave businesses send a PDF with each e-invoice, so that businesses not yet covered by the mandate can read it, unless the recipient expressly and voluntarily agrees to receive the structured invoice alone |
| 6 Oct 2028 | All remaining businesses and professionals must issue and receive structured invoices and report statuses; second-wave self-employed individuals and income-attribution entities report statuses voluntarily until 6 October 2029 |
| 6 Oct 2029 | Status reporting becomes mandatory for second-wave self-employed individuals and income-attribution entities; voluntary until then |
Which formats does Spain B2B e-invoicing accept?
Royal Decree 238/2026 admits UBL, CII, EDIFACT and Facturae. Invoices issued or interconnected through AEAT's public solution must follow the EN 16931 semantic data model in UBL syntax (Order HAC/1028/2026, article 3.1), and private platforms also send a faithful copy of each invoice to the public solution in UBL.
What does invoice status reporting involve?
Under Royal Decree 238/2026, the recipient of a Spanish B2B e-invoice will have to report commercial acceptance or rejection and full payment, with the date of each, within four days, excluding Saturdays, Sundays and national public holidays. Partial acceptance, partial payment and assignment of the invoice can be reported voluntarily.
The duty starts with each business's own wave: 6 October 2027 for the first wave and 6 October 2028 for the rest. The exception is second-wave self-employed individuals and entities under the income-attribution regime, for whom status reporting is voluntary until 6 October 2029 (Royal Decree 238/2026, transitional provision 3).
Those dates usually sit in accounts payable rather than in the invoicing system, so it pays to bring accounts payable and procurement into the project early. A four-day cycle also means statuses will flow continuously instead of in a weekly batch.
One further effect is worth planning for. Recipients will have to report the effective payment date and the payment due date to AEAT's public solution (Royal Decree 238/2026, article 12), and the decree's preamble names reliable data on actual payment periods as a goal, to reduce late payment. Payment performance towards Spanish suppliers will therefore become reported data.
How do I know which wave my company is in?
The €8 million threshold uses the volume of operations of the previous calendar year, as defined in article 121 of the Spanish VAT Law. It is measured per entity rather than per group, and on a different basis from the Verifactu thresholds. A single Spanish entity above it starts in October 2027 even when the group sits below.
Spain B2B e-invoicing sits alongside Verifactu, TicketBAI and the SII. Each has its own scope and its own calendar.
What is still to be confirmed?
Three points remain open. AEAT has not announced a testing period beyond the two months of guaranteed availability, its detailed technical specifications (schemas, validation rules, authentication) can still change before 2027, and threshold edge cases, such as a first year of activity or a non-established taxpayer, need confirming case by case.
Key takeaways
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Settle your wave per entity. One Spanish entity whose previous-year volume of operations exceeded €8 million starts in October 2027, even when the group as a whole does not.
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Protect the testing window. Finish everything that does not depend on AEAT's platform before 6 August 2027, the latest date it can go live, so the testing window goes to testing.
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Bring accounts payable in early. Acceptance and payment dates live there, not in the invoicing system, and they will have to be reported within four days, excluding weekends and national public holidays.
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Agree PDF handling with partners. In the first twelve months, first-wave businesses send a PDF with each e-invoice, so that businesses not yet covered can read it, unless the recipient expressly agrees to receive the structured invoice alone.
Planning your move to Spain B2B e-invoicing? fiskaly is a cloud-based, API-first provider of fiscalization and VAT compliance, and our compliance team can walk through scope, formats and invoice status reporting with you, and help you map the timeline to 6 October 2027. fiskaly SIGN ES already covers Verifactu, TicketBAI and the SII.
