Spain sets rules for its public e-invoicing platform, SPFE

Spain sets the rules for its public e-invoicing platform

7 October 2026: Spain's finance ministry has published Order HAC/1028/2026, which regulates the public electronic invoicing solution (SPFE) run by the tax agency, the Agencia Tributaria. The platform is the state's own channel for the mandatory business-to-business e-invoicing that Spain adopted under the Crea y Crece law, Law 18/2022. The order entered into force on 6 October 2026, and the compliance clocks run from that day.

Not yet independently verified. We read the order's articles but not its annexes in full, and the order does not give the date the platform must be ready by. Penalties come from the underlying laws, which the order does not restate. We will update this when it can be confirmed, and remove this note.

The tax agency's notice sets three deadlines, counted from entry into force:

• 6 October 2027: businesses and professionals with turnover above €8 million must issue, send and receive e-invoices, and report invoice statuses and payments.
• 6 October 2028: all other businesses and professionals must issue, send and receive e-invoices. Legal entities with turnover of €8 million or less must also report statuses and payments.
• 6 October 2029: natural persons and entities under the income attribution regime must report statuses and payments.

Using the SPFE is optional. A business may issue and receive invoices through private software, through the SPFE or through a mix of both. The agency describes the platform as a basic alternative aimed mainly at small businesses and professionals, and it also acts as a repository for every e-invoice and for payment-status data.

The order puts duties on software providers. Invoices must follow the EN 16931 semantic model in UBL syntax, with Spanish-specific fields set out in Annex I; the text does not mention Facturae. A business or platform that does not issue through the SPFE must send a simultaneous faithful copy of each invoice in UBL, flagged as a copy, and the agency rejects duplicates and invalid copies with reasons, so the issuer must correct and resend. Private platforms that exchange invoices through the SPFE must automate access to retrieve their clients' received invoices and make them available immediately.

Recipients report rejection, the due date and the full payment date through the status messages in Annex II. Absent a rejection or a corrective invoice, an invoice is presumed accepted. If the platform is unavailable for more than 24 hours through its own fault, submissions can be made within four business days of the fix. Access uses qualified electronic certificates, or Cl@ve for the web forms.

The order says the platform must be available to obliged parties at least two months before the first effective application, without stating that date, and it contains no penalty regime of its own. Our billing and invoicing software category lists four products, for teams comparing vendors that will need to meet the copy and retrieval rules.

Sources

• Agencia Tributaria: Public Electronic Billing Solution (SPFE), 7 October 2026
• BOE: Order HAC/1028/2026 (BOE no. 247, 5 October 2026), 5 October 2026