Spain E-Invoicing Mandate: Deadlines Start 6 October 2027 as Verifactu Slips Toward 2028

Spain's e-invoicing mandate finally has fixed dates. On 5 October 2026 the Official State Gazette (BOE) published Order HAC/1028/2026, the ministerial order that regulates the public e-invoicing platform and, by entering into force on 6 October 2026, started the countdown written into Royal Decree 238/2026. Businesses with turnover above EUR 8 million must issue, receive and report on structured e-invoices from 6 October 2027; everyone else follows on 6 October 2028. In the same week, the Ministry of Finance announced that the separate Verifactu invoicing-software obligation, still legally due on 1 January 2027, is expected to move to October 2028 so that the two regimes land together. This article sets out what is now law, what is still only announced, and what a CFO or IT manager in Spain should do before the first deadline.

Two regimes, one calendar: Crea y Crece e-invoicing vs Verifactu

Spain has been building two separate obligations in parallel, and much of the confusion in the market comes from mixing them up.

The first is mandatory B2B e-invoicing under Law 18/2022 ("Crea y Crece"), developed by Royal Decree 238/2026 of 25 March 2026 (BOE 31 March 2026) and now activated by Order HAC/1028/2026. Its purpose is commercial: every invoice between businesses established in Spain must be a structured electronic document, exchanged through interoperable platforms, with the recipient reporting acceptance and payment so that the state can measure late payment. Its owner is the Ministry of Economy, with the tax agency (AEAT) running the public platform.

The second is Verifactu, the invoicing-software requirements of Royal Decree 1007/2023 (the "SIF" regulation). It is a tax-control measure: invoicing software must produce hash-chained, QR-coded invoice records that are either sent to the AEAT in real time (the VERI*FACTU mode) or kept, signed and available on request. Its owner is the Ministry of Finance.

Until October 2026 the two calendars were out of step. The B2B mandate had no start date because its ministerial order had not been published, while Verifactu had been postponed twice, most recently by Royal Decree-law 15/2025 (BOE 3 December 2025) to 1 January 2027 for corporate income tax payers and 1 July 2027 for everyone else. Order HAC/1028/2026 fixed the first problem; the Ministry's 5 October 2026 note addressed the second, but only as an announcement.

The Spain e-invoicing mandate timeline after Order HAC/1028/2026

Royal Decree 238/2026 counts all of its deadlines from the entry into force of the order on the public platform. The AEAT confirmed the resulting dates on 7 October 2026:

Two points matter for groups with Spanish subsidiaries. First, the threshold is tested per taxpayer, on the previous calendar year's turnover, so a Spanish entity of an international group can fall into the 2027 wave even if its parent handles invoicing centrally. Second, the receiving obligation lands on the same date as the issuing obligation. A supplier in the 2027 wave will send e-invoices to customers that are not yet obliged to issue them, and those customers are deemed to receive through the public platform unless they have declared a private one.

How the Spanish model works: SPFE, private platforms and the UBL copy

Spain has chosen a hybrid model rather than a single clearance portal. Businesses may use private e-invoicing platforms, the AEAT's free Solución Pública de Facturación Electrónica (SPFE), or both. The decree's key design choices are:

• Semantic model and syntaxes. Invoices follow the EN 16931 semantic model and may be expressed in UBL, CII, EDIFACT or Facturae. UBL is the SPFE's reference syntax, and Peppol BIS Billing is accepted on private platforms as a UBL profile. See our EN 16931 explainer for how these syntaxes relate.
• Faithful copy to the SPFE. A private platform that does not issue through the SPFE must send a faithful electronic copy of every invoice, in UBL, to the public platform at the moment of issuance. The SPFE therefore becomes a national invoice repository even for businesses that never log into it.
• Interoperability. Private platforms must be able to convert between all admitted formats, must interconnect with any other platform when a client asks, must complete the interconnection within one month and may not charge the requesting platform for it. The decree lists ISO/IEC 27001 and AS2 or AS4 transport among the operator requirements.
• Signature and identifier. Invoices issued through private platforms carry an advanced electronic signature. Every invoice has a unique code built from the issuer's NIF, invoice number and series, and issue date.
• Default routing. If a recipient has not publicly identified a private entry point, the SPFE is its entry point by default.

For companies that already run EDI with Spanish retailers or automotive customers, the acceptance of EDIFACT is significant: an existing EDI invoice flow can remain the commercial channel, provided the operator also generates the UBL copy for the SPFE and handles the status messages. Our comparison of EDI invoicing and e-invoicing explains why the two usually coexist rather than replace each other.

Invoice status reporting: the obligation CFOs underestimate

The feature that distinguishes Spain from most EU mandates is mandatory status reporting by the recipient. Under Articles 10 and 12 of Royal Decree 238/2026, the recipient must inform the issuer of the commercial acceptance or rejection of the invoice, with its date, and of full payment, with its effective date. Partial acceptance, partial payment and assignment of the receivable can be reported optionally. Full payment, payment dates and due dates must also be communicated to the SPFE, whether or not the business uses it to exchange invoices. The decree sets a four-day window for these communications, and an invoice that is not rejected is presumed accepted.

This is a finance-process change, not an IT change. Accounts payable teams will need a defined rejection step, a reliable payment-date feed from the ERP or bank, and a way to push both to the platform within days. The data goes to the Ministries of Economy and Industry and feeds the national late-payment observatory, which is the political reason the mandate exists at all. Compare this with France, where the e-invoicing mandate uses a similar platform model but places lifecycle statuses mainly in the hands of the supplier's platform.

What stays out of scope

The mandate covers business-to-business invoices where the recipient has its seat, permanent establishment or residence in Spain. Invoices to consumers and to counterparties not established in Spain remain outside it, as do simplified invoices (unless they are the qualified kind that identifies the recipient). Regulated electricity and gas market operations and IATA clearing-house settlements are excluded by the decree, and the Basque Country and Navarre will be handled through agreements between their regional tax authorities and the AEAT. During the first twelve months of their obligation, businesses in the 2027 wave must attach a legible PDF to each e-invoice so that recipients not yet equipped can read it.

Verifactu: what is law and what is only announced

As of early November 2026 the legally binding Verifactu dates are still those set by Royal Decree-law 15/2025: 1 January 2027 for corporate income tax payers and 1 July 2027 for self-employed professionals and other taxpayers. On 5 October 2026 the Ministry of Finance issued an informative note stating that it plans to move the outstanding obligations to October 2028, to coincide with the e-invoicing date for businesses at or below EUR 8 million, and that a later amendment will align the system with the EU's ViDA package. The note does not name a day, does not say whether larger companies get the same date, and has not yet been followed by a royal decree in the BOE. Until that instrument is published, the 2027 dates remain enforceable.

The practical consequence is that a company already preparing Verifactu-compliant software for January 2027 should not stop. The Ministry itself says the integrity and traceability guarantees will remain substantially equivalent after the change, and the same hash, QR and record-keeping logic will be needed whenever the date lands. What the announcement does change is budgeting: if the postponement is enacted, the two projects can be merged into a single 2027–2028 programme instead of two separate go-lives.

A preparation checklist for the 6 October 2027 wave

For a Spanish entity above EUR 8 million, eleven months is not long once ERP change windows and supplier onboarding are counted. The sequence that works in other mandates applies here too:

1. Confirm which legal entities exceed the EUR 8 million threshold on 2026 turnover, and which will exceed it on 2027 turnover for the following year.
2. Decide the platform model: private platform with UBL copy to the SPFE, SPFE only, or both. Most mid-sized and large companies with existing EDI or multi-country flows will choose a private operator for the commercial channel.
3. Map the EN 16931 data set against your ERP invoice output, with special attention to the unique identifier fields and the signature step.
4. Design the status-reporting process on the AP side: rejection criteria, payment-date source and the four-day window.
5. Plan the PDF attachment for the first twelve months and the public identification of your entry point.
6. Keep the Verifactu workstream alive, re-scheduling it only when an amending decree appears in the BOE.

If Spain is one of several mandates on your roadmap, the Complete Guide to Global E-Invoicing Compliance describes how to build a single compliance layer rather than a project per country, and the Infinite Compliance Tracker keeps the dates current as decrees are published. If your Spanish flows run over Peppol, our guide on choosing a Peppol access point provider covers the operator criteria that also apply to Spanish private platforms.

Frequently asked questions

When does mandatory e-invoicing start in Spain?

Businesses and professionals with turnover above EUR 8 million must issue, receive and report on e-invoices from 6 October 2027. All other businesses follow on 6 October 2028, and individuals must start status reporting on 6 October 2029. The dates were triggered by Order HAC/1028/2026, which entered into force on 6 October 2026.

Is Verifactu the same as Spain's B2B e-invoicing mandate?

No. Verifactu (Royal Decree 1007/2023) sets technical requirements for invoicing software, such as hash-chained records and QR codes, and is a tax-control measure. The B2B e-invoicing mandate (Royal Decree 238/2026) requires structured invoices to be exchanged between businesses through interoperable platforms with status reporting. They have separate legal bases and, for now, separate deadlines.

Has Verifactu been postponed to 2028?

Not yet in law. On 5 October 2026 the Ministry of Finance announced its intention to move Verifactu to October 2028, but as of early November 2026 no amending royal decree has been published in the BOE. The binding dates remain 1 January 2027 for corporate income tax payers and 1 July 2027 for other taxpayers.

Which invoice formats are accepted under the Spanish e-invoicing mandate?

Invoices must follow the EN 16931 semantic model and may use UBL, CII, EDIFACT or Facturae syntax. UBL is the reference syntax of the public platform (SPFE), and private platforms that do not issue through the SPFE must send a faithful UBL copy of every invoice to it.

Next step

Infinite IT Solutions operates e-invoicing and EDI compliance services across the EU and the Middle East, including interoperable platform connectivity, EN 16931 format conversion and status-message handling. If you need to bring a Spanish entity into compliance by October 2027, or fold Spain into an existing multi-country programme, contact our team to discuss your scope.