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]
Links
- Proyecto de OM Solución Pública de Facturación Electrónica [↗︎]
- Public Electronic Invoicing Solution (SPFE) [↗︎]
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]
🔗 Links
- The Invoicing Hub – Spanish B2B e-invoicing technical guidance published (1 June 2026) [theinvoicinghub.com]
- Marosa VAT – E-invoicing in Spain: Complete Guide [marosavat.com]
- AEAT – Facturación electrónica obligatoria (official page) [sede.agenc…ria.gob.es]
- VATupdate – Spain Publishes Royal Decree Implementing Mandatory B2B Electronic Invoicing [vatupdate.com]
- RTC Suite – Spain’s Mandatory B2B e-Invoicing Takes Shape: RD 238/2026 and the Draft Ministerial Order [rtcsuite.com]
- Vertex – Spain’s 2026 E-Invoicing Regulations Explained [vertexinc.com]
Briefing document & Podcast: Spain – E-Invoicing and E-Reporting – VATupdate
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