Spain Tightens the Screws on Its Public Invoicing Platform Before the Rules Are Signed

• At a seminar on 10 September 2026, the revo session material reports that the Agencia Tributaria presented the updated draft Ministerial Order developing the Solución Pública de Facturación Electrónica (SPFE), the public platform that will operate alongside private platforms under Law 18/2022 (Ley Crea y Crece) and RD 238/2026.
• AEAT was working towards entry into force of the Order on 1 October 2026, with B2B e-invoicing and status reporting from 1 October 2027 for businesses above EUR 8 million volume of operations, 1 October 2028 for the rest, and 1 October 2029 for status reporting by individuals and income-attribution entities below the threshold.
• Key technical points: SPFE works exclusively in UBL 2.5 aligned with EN 16931, uses an ebXML transport envelope, returns an encrypted localizador for retrieval, and applies three validation layers; a test environment was targeted for October 2026, but only after publication in the BOE.

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Extended article

Legal context. The obligation originates in Law 18/2022 of 28 September (Ley Crea y Crece), which extends mandatory issuance, transmission and receipt of electronic invoices to domestic B2B relations, requires interoperability between platforms, and provides for invoice status information to control payment periods. Real Decreto 238/2026 of 25 March develops the system and entered into force on 20 April 2026; its business obligations apply in phases calculated from entry into force of the implementing Ministerial Order. The draft Order at the time of the seminar contained 11 articles, two additional provisions, one final provision and two annexes. The public consultation closed on 8 May 2026 and the Directive (EU) 2015/1535 notification procedure closed on 6 August 2026. [revo | PDF]

Two routes, not a blanket clearance model. SPFE performs four functions: universal repository of faithful copies, interconnection with and between private platforms, payment status management, and a free invoicing solution. Where the invoice is issued and exchanged through a private platform, a structured electronic faithful copy must be sent to SPFE simultaneously with issuance; where SPFE itself was used for issuance or interconnection, no additional copy is required. Revo’s reading of the session is that the private-platform route is not presented as universal prior AEAT authorisation before the customer receives the invoice — SPFE validates submissions before admitting them, but no tax-approval stamp was introduced.

Identification and retrieval. The unique invoice code concatenates invoice series and number, issue date and supplier NIF, carried in UBL through BT-31 or BT-32. AEAT additionally returns a separate encrypted localizador for efficient retrieval of the stored XML — described as a technical retrieval reference, not an invoice-authorisation UUID. SPFE checks for duplicates: an existing faithful copy must be withdrawn before an original with the same identification can be submitted.

Status reporting and payment. The customer reports rejection (with reason) or full payment, including actual payment date and due date; SPFE treats an admitted invoice as “Accepted” by default. The supplier may voluntarily report collection or non-payment, and a new optional financing indicator explains why the supplier’s collection date differs from the customer’s payment date. A simplification treats the customer’s reporting obligation as fulfilled where the invoice or copy records a payment date on or before issue matching the transaction date or tax point, unless the customer files an express payment report. Notably, SPFE has no partial-payment message — payment and collection messages concern the full invoice amount.

Annex I data model changes. The bespoke corrective-invoice extension is removed in favour of the standard supporting-document group BG-24 for correction type, method and corrected amounts. New fields and list L9 cover excise duties (hydrocarbons, alcohol, tobacco, electricity, coal, non-reusable plastic packaging, landfill and incineration, among others), while the new BG-34 group from UNE-EN 16931-1:2026 handles third-party charges, withholdings and IEDMT. Self-billing is confirmed (document types 389 and 471), and a UBL ApplicationResponse cancellation message implements Article 3.5, allowing withdrawal of an invoice for a non-existent operation with full traceability.

Technical services. Three channels exist: AEAT’s free invoicing application (last-resort, mainly for SMEs), a consultation and status form, and synchronous web services requiring an electronic certificate. The service catalogue includes SendInvoiceSOAP, CancelInvoiceSOAP, GetInvoicesSOAP, GetRegisteredInvoiceSOAP, DownloadInvoicesByIDSOAP, DownloadInvoicesByLOCSOAP, plus CustomerInvoiceEventsSOAP and SupplierInvoiceEventsSOAP. Batches of 1 to 100 invoices up to 5,120 KB each were shown; binary attachments are not admitted (URL references only); queries are capped at 1,000 invoices and downloads at 100. Validation runs in three layers: UBL 2.5 schema, EN 16931 Schematron, and AEAT-specific checks.

Practical warnings for taxpayers. AEAT stated explicitly that SPFE is not an invoice storage or backup service — retention responsibility stays with the business. If AEAT suffers a technical outage attributable to it exceeding 24 hours, invoices and copies may be submitted within four working days after resolution. Cancellation in SPFE removes the registration from normal consultation but does not replace a corrective invoice where one is required. No replacement of, or new exemption from, SII was announced. The ebXML transport approach was described as compatible with AS4/Peppol and supportive of future ViDA interoperability, but this does not mean an existing Peppol connection removes the need for Spanish implementation work.

Next steps. Before deploying the test environment, AEAT will publish explanatory technical documentation on its https://www.agenciatributaria.es/AEAT.desarrolladores/Desarrolladores/Desarrolladores.html — service catalogues for businesses and platforms, submission standards, authentication and representation rules, message examples, WSDL files and validation documents.

Caveat: the Ministerial Order was still a draft at the date of the session; all dates and content remain subject to change before publication in the BOE.

Other sources

• VATCalc — Spanish B2B Crea y Crece e-invoice and e-reporting update
• Link to the Webinar