AEAT launches dedicated portal for mandatory B2B e-invoicing and the Public Electronic Invoicing Solution

Summary

• The Spanish Tax Agency, AEAT, has opened a dedicated section covering the Solución Pública de Facturación Electrónica, or SPFE, and Spain’s mandatory B2B e-invoicing system. The portal currently includes introductory guidance, scope information, implementation dates and references to the applicable legislation. Additional frequently asked questions and detailed technical documentation are expected as implementation progresses. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

• Based on the implementation calendar published by the AEAT, mandatory electronic invoicing will apply from 6 October 2027 to businesses and professionals whose annual turnover exceeds EUR 8 million, and from 6 October 2028 to other businesses and professionals. Separate deadlines apply to the obligation to report invoice and payment statuses. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]
• The SPFE B2B e-invoicing system should not be confused with VERI*FACTU. SPFE regulates the electronic issuance, delivery and receipt of invoices between businesses, together with invoice-status reporting. VERIFACTU concerns the integrity and traceability of billing records generated by invoicing software and, under the VERIFACTU option, their immediate transmission to the AEAT. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

AEAT creates a dedicated information portal

The Spanish Tax Agency has launched a dedicated section of its electronic office for the Solución Pública de Facturación Electrónica, abbreviated as SPFE. The portal is intended to become the central AEAT reference point for Spain’s mandatory electronic invoicing system between businesses and professionals. It currently provides sections on general questions, the implementation timetable and the relevant legal framework. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

The new portal confirms that the Spanish model is intended to support the obligation to issue, send and receive electronic invoices for domestic commercial relationships between businesses and self-employed professionals. It also covers the reporting of specified invoice statuses, particularly information relating to the acceptance and payment of invoices. The policy objectives include reducing late payment, improving access to reliable payment information, supporting the digitalisation of smaller businesses and reducing administrative costs. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

Although the opening of the portal represents an important implementation milestone, the currently available content remains relatively high-level. Businesses should therefore monitor the portal for the publication and subsequent updating of FAQs, schemas, validation rules, connectivity instructions, testing arrangements and other technical material required for implementation.

Implementation timetable

According to the implementation calendar published by the AEAT, the relevant ministerial order governing the public electronic invoicing solution entered into force on 6 October 2026. This date starts the statutory and regulatory countdown for the application of the Spanish B2B e-invoicing obligations. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

The obligation to issue and receive electronic invoices will apply as follows:

• From 6 October 2027: businesses and professionals whose VAT turnover exceeded EUR 8 million during the immediately preceding calendar year.
• From 6 October 2028: all other businesses and professionals falling within the scope of the mandate.

During the first 12 months of the mandate, businesses in the first implementation wave must accompany their electronic invoices with a PDF document that ensures invoice readability for recipients that may not yet be fully integrated into the electronic exchange environment. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

The reporting of invoice and payment statuses follows a partly separate timetable:

• 6 October 2027: businesses and professionals with annual turnover exceeding EUR 8 million.
• 6 October 2028: other businesses and professionals that are legal persons or entities.
• 6 October 2029: other businesses and professionals that are natural persons or entities operating under an income-attribution regime.

Private electronic invoicing platforms will also become subject to specific exchange, interoperability and related obligations from 6 October 2027. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

What the SPFE is intended to do

The SPFE will form part of the broader Spanish electronic invoicing architecture. It is intended to provide a public solution through which electronic invoices can be exchanged and the required invoice statuses can be communicated. Private electronic invoicing platforms may continue to operate, but they will need to meet the regulatory requirements governing interoperability and connectivity with the wider Spanish system. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

The mandate does not fundamentally replace Spain’s existing substantive VAT invoicing rules. Whether an invoice is required, which party is responsible for issuing it, what information must appear on it and how corrections must be made will continue to be determined principally under the Spanish VAT legislation and the Spanish invoicing regulation. The electronic invoicing framework changes the required format and transmission process for transactions within scope, rather than creating a completely separate set of substantive VAT invoicing rules. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

SPFE and VERI*FACTU are separate regimes

Companies should avoid treating the SPFE and VERI*FACTU as interchangeable concepts.

The SPFE and mandatory B2B e-invoicing regime govern how invoices are issued, transmitted and received between Spanish businesses and professionals. They also introduce requirements for communicating invoice lifecycle events, particularly acceptance and payment information. The commercial policy focus is strongly linked to combating late payment and increasing transparency over actual payment periods. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

VERI*FACTU, by contrast, is one of the permitted operating models for a Spanish Sistema Informático de Facturación, or SIF. In the VERIFACTU model, the invoicing system sends invoice records online to the AEAT in a continuous, secure, automatic and immediate manner. The alternative non-VERIFACTU model does not continuously transmit the records, but must retain them locally under stricter requirements concerning integrity, conservation, accessibility, traceability, electronic signatures and event logging. [sede.agenc…ria.gob.es], [boe.es]

VERIFACTU therefore concerns the tax-control record generated by the invoicing system, whereas the B2B e-invoicing mandate concerns the invoice exchanged with the customer. A VERIFACTU transmission to the AEAT does not, by itself, constitute delivery of the electronic invoice to the customer. Equally, sending an electronic invoice to a customer through the SPFE or a private platform does not automatically demonstrate that the underlying invoicing software complies with the SIF and VERI*FACTU requirements. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

VERI*FACTU requirements remain relevant

Under the VERI*FACTU model, billing records are transmitted online to the AEAT as they are generated. The invoice generally contains a QR code and the wording indicating that it is verifiable through the AEAT electronic office. The recipient can use the QR functionality to verify whether the corresponding record has been registered with the tax authority. [sede.agenc…ria.gob.es], [boe.es]

The technical rules are principally contained in Royal Decree 1007/2023 and Order HAC/1177/2024. These rules address record formats, hash-based chaining, traceability, electronic signatures where applicable, event records, system declarations and the electronic transmission of invoice records. The applicable SIF deadlines were extended to 1 January 2027 for corporate income tax taxpayers and 1 July 2027 for the other taxpayers covered by the regulation. [boe.es], [boe.es]

Businesses falling within the Spanish Immediate Supply of Information system, or SII, are generally excluded from the SIF regulation for the relevant invoicing activities because their VAT records are already reported electronically under the SII framework. Specific exclusions also apply to certain invoices issued materially by the customer or a third party where the relevant transactions are included in SII reporting. [boe.es], [boe.es]

Business implications

Companies operating in Spain should manage SPFE and VERIFACTU as connected but distinct implementation workstreams. The SPFE workstream should focus on invoice formats, customer and supplier connectivity, platform interoperability, invoice delivery, receipt processing and invoice-status reporting. The VERIFACTU workstream should focus on billing-system architecture, generation and chaining of invoice records, QR requirements, record transmission, exception handling and evidence that the software meets the regulatory requirements. [sede.agenc…ria.gob.es], [sede.agenc…ria.gob.es]

Businesses should now assess which Spanish entities and systems are covered by each regime, identify whether they are included in SII, determine the applicable implementation wave and map all invoicing applications that generate Spanish invoices. Particular attention should be given to decentralised billing tools, point-of-sale systems, self-billing arrangements, third-party billing providers and ERP modules that may constitute separate invoicing systems. [sede.agenc…ria.gob.es], [boe.es]

The opening of the AEAT’s SPFE portal provides businesses with an official point of reference for the next implementation phase. However, organisations should continue monitoring the portal for additional FAQs and technical specifications before finalising system designs and connectivity decisions.

Official sources

• AEAT: Factura electrónica, SPFE
• AEAT: SPFE implementation calendar
• AEAT: Sistemas Informáticos de Facturación and VERI*FACTU
• BOE: Order HAC/1177/2024

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