AEAT Publishes Technical Guidance on the Public Electronic Invoicing Solution (SPFE) for Mandatory B2B E-Invoicing

Summary

🇪🇸 Two new technical documents released: Spain’s tax authority (AEAT) published on 1 June 2026 two key documents detailing the role, functionalities, business rules, and IT infrastructure specifications of the SPFE (Solución Pública de Facturación Electrónica), the free public platform for mandatory B2B e-invoicing. [theinvoicinghub.com]
⚙️ EN 16931:2026 & UBL 2.5 confirmed as the technical standard: The SPFE will support the upcoming EN 16931:2026 standard based on XML UBL 2.5 syntax, with secure connectivity via REST APIs, AS4, and web services, and a sandbox testing environment available from 1 October 2026. [theinvoicinghub.com]
📅 Phased timeline reconfirmed: Large companies (turnover > €8M) must comply by October 2027, smaller businesses and professionals by October 2028, and self-employed individuals (turnover < €8M) must begin reporting invoice statuses by October 2029. [theinvoicinghub.com], [marosavat.com]

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Article

On 1 June 2026, the Spanish Tax Authority (Agencia Estatal de Administración Tributaria – AEAT) released two new technical documents providing detailed guidance on how the SPFE (Solución Pública de Facturación Electrónica) — Spain’s free public e-invoicing platform — will function under the upcoming mandatory B2B e-invoicing regime. [theinvoicinghub.com]

Background: Spain’s Regulatory Framework

Spain’s mandatory B2B e-invoicing obligation was first introduced under Law 18/2022 (Ley Crea y Crece) and operationalised through Royal Decree 238/2026, published in the BOE on 31 March 2026. A draft Ministerial Order was subsequently released for public consultation in April 2026, setting out the technical specifications and confirming the expected entry into force on 1 October 2026. [marosavat.com], [rtcsuite.com]

Spain has opted for a hybrid model where companies can exchange e-invoices via:

Private interoperable platforms, which must simultaneously send a faithful electronic copy (copia fiel) to the SPFE; or
The SPFE itself, a free public platform managed by AEAT, serving both as a direct issuance tool and as the universal repository for all B2B e-invoices. [theinvoicinghub.com], [marosavat.com]

Document 1: Ministerial Order Project for the SPFE

The first document —“Proyecto de OM Solución Pública de Facturación Electrónica” — focuses on business rules, invoice lifecycle, and functional workflows. Key areas covered include: [theinvoicinghub.com]

Governance and role of the SPFE: How the platform receives, validates (syntactic and semantic) UBL e-invoices, and manages their distribution to recipients.
Invoice status management (Ciclo de vida): Mandatory and optional statuses of an e-invoice, including acceptance (presumed if no rejection is reported), rejection, payment date, and effective payment.
Transmission and access methods: Submission via web forms for small businesses and automated API flows for larger volumes.
Centralized business directory (Directorio de empresas): Ensuring accurate invoice routing.
Interoperability within the hybrid model: How the SPFE will interact with private platforms to exchange both e-invoices and their corresponding statuses. [theinvoicinghub.com]

Document 2: Technical and IT Infrastructure Specifications

The second document —“Public Electronic Invoicing Solution (SPFE)” — focuses on the technical and IT architecture, covering: [theinvoicinghub.com]

API and connectivity specifications: Secure protocols including REST APIs, AS4, and web services for machine-to-machine (M2M) connections.
Security and authentication: Mandatory frameworks including electronic certificates and digital signatures to secure transmissions and verify platform identities.
Data schemas and message formats: Strict XML structures and validation syntax required for both e-invoices and their tracking message envelopes.
Sandbox testing environment (entorno de pruebas): A testing environment will be made available for software developers to validate integration before go-live — not before 1 October 2026 (the expected publication date of the Ministerial Order). [theinvoicinghub.com]

Key Technical Standard: EN 16931:2026 / UBL 2.5

Both documents confirm that the SPFE will support the EN 16931:2026 standard based on the forthcoming XML UBL 2.5 syntax, which is currently being finalised for official publication. E-invoices will undergo dual validation: [theinvoicinghub.com], [marosavat.com]

Syntax validation via XSD (XML Schema Definition) checking UBL structure.
Semantic validation via a Schematron model based on the EN 16931 standard (2026 version).

Implementation Timeline (Reconfirmed)

Deadline	Obligation	Scope
1 October 2027	Mandatory e-invoicing (issue & receive) + payment status reporting	Large companies (turnover > €8M)
1 October 2028	Mandatory e-invoicing (issue & receive) + payment status reporting	All other businesses and professionals
1 October 2029	Mandatory invoice status reporting	Self-employed individuals (turnover < €8M)

During the first 12 months of mandatory compliance, large businesses must accompany each e-invoice with a readable PDF copy for recipients not yet on the system. [theinvoicinghub.com], [marosavat.com]

Expected Additional Technical Documentation

Several additional documents are expected to be published on the Software Developers Portal (Portal de Entidades Desarrolladoras) prior to the SPFE deployment: [theinvoicinghub.com]

Service catalogue for companies and platforms
Submission standards
Authentication and representation rules
Applicable limitations
Error lists
WSDL for accessing services
XSD schemas for custom extensions and references to OASIS (UBL)
Validation documents (Schematron)
Illustrative examples of different messages

ViDA Alignment

Spain’s B2B e-invoicing mandate aligns with the EU’s VAT in the Digital Age (ViDA) initiative, positioning Spain as one of the early movers in implementing comprehensive structured e-invoicing and digital reporting requirements within the EU. [rtcsuite.com], [vertexinc.com]

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