The Official Gazette of the Spanish State has just published Order HAC/1028/2026, of October 2, regulating the public e-invoicing platform (…). The Order completes the regulatory framework required to roll out e-invoicing in Spain and sets out the key dates for compliance with this new obligation for legal entities and individuals carrying on business or professional activities.
The legal basis for mandatory e-invoicing in transactions between businesses and professionals, whether individuals or legal entities —B2B transactions—, is article 2 bis of Act 56/2007, on measures to promote the information society, as amended by Act 18/2022, of September 28, on business creation and growth (the "Create and Grow Act"). The implementing regulations were approved by Royal Decree 238/2026, of March 25, which we analyzed in our Legal Flash | Regulation approved on mandatory e-invoicing for B2B transactions.
As discussed in that Legal Flash, this new obligation will be introduced in phases, with several implementation dates linked to the entry into force of Order HAC/1028/2026.
Specifically, the Order enters into force today, October 6, 2026 (a few days later than originally expected). The compliance deadlines for mandatory B2B e-invoicing depend on the annual turnover of the affected businesses and professionals, calculated in accordance with article 121 of Act 37/1992, the Spanish VAT Act. The relevant dates are:
- October 6, 2027, for businesses and professionals whose annual turnover exceeded €8 million in the previous calendar year (12 months after the entry into force of Order HAC/1028/2026).
- October 6, 2028, for all other businesses and professionals (24 months after the entry into force of Order HAC/1028/2026).
- October 6, 2029, for the specific obligation imposed on individuals carrying on business or professional activities with annual turnover below €8 million to report invoice status information (36 months after the entry into force of Order HAC/1028/2026).
The Order also sets out the technical requirements for the public e-invoicing platform and the services it must provide: (i) issuing electronic invoices, (ii) interconnecting the various private e-invoicing platforms, and (iii) acting as a central repository for electronic invoices through the submission of a faithful electronic copy of each invoice.
Mandatory e-invoicing and Veri*factu: different obligations
This new e-invoicing obligation should not be confused with the separate requirements applicable to invoicing software under the rules commonly known as Veri*factu. Those rules affect businesses and professionals that do not keep their VAT records through the Spanish Tax Agency’s Immediate Supply of Information (SII) system. Among others, VAT taxpayers whose annual turnover exceeded €6,010,121.04 in the previous calendar year are required to use the SII system. For more information on the key aspects of this obligation affecting invoicing software, see our Legal Flash | Invoicing programs and Veri*factu system, which analyzes the regulations approved by Royal Decree 1007/2023.
The deadline for adapting invoicing software to the requirements of Royal Decree 1007/2023 was postponed to 2027 following the approval of Royal Decree-Law 15/2025, as discussed in our Post | Deadline for adapting invoicing systems and software is extended. However, the Ministry of Finance has just published a press release entitled “Expected amendment of the deadlines for the application of the outstanding obligations (...) arising from the Regulation on Invoicing Software Systems (Royal Decree 1007/2023) and alignment with the electronic invoicing system.” According to the announcement, the deadline for adapting invoicing software will be postponed again, until October 2028, to align it with the mandatory e-invoicing timetable discussed in this post. We will monitor the approval of the new deadline closely.
For more information, please contact our specialists through the Knowledge and Innovation Area.