Orden HAC/1028/2026 regulates the state platform SPFE and started the countdown. This article sets out the timetable, the reporting of invoice and payment statuses and the requirements placed on private exchange platforms.
On 5 October 2026 the Orden HAC/1028/2026 of 2 October was published in the Boletín Oficial del Estado. It regulates the state platform Solución Pública de Facturación Electrónica (SPFE) and entered into force on 6 October 2026. That date starts the periods set out in Ley 18/2022 and in Real Decreto 238/2026.
Spain is introducing two obligations on separate deadlines. The first covers issuing, sending and receiving electronic invoices. The second requires the reporting of invoice and payment statuses to the SPFE. The second obligation does not end when the invoice is sent. It begins there.
The Agencia Tributaria counts every period from the entry into force of the order. The relevant figure for the classification is the turnover for VAT purposes in the immediately preceding calendar year.
Note: during the first twelve months, large businesses must accompany the electronic invoices they issue with a PDF document that ensures legibility for the other businesses and professionals. This requirement applies to that period only.
The reporting runs in two directions. Part of the information goes to the state platform, another part to the issuer of the invoice. The obligation falls on the recipient.
The full payment, the payment date and the date on which the invoice falls due.
The commercial acceptance or rejection of the invoice with its date, and the effective full payment.
Issuing a structured invoice and sending it is therefore not sufficient. The system has to keep receiving data after dispatch, and that data does not usually originate in invoice issuing but in accounts receivable and accounts payable. Who holds the payment data is a question to settle before the implementation starts.
Background: the Agencia Tributaria names the reduction of late payment as a purpose of the rules. The reported data is intended to produce reliable information on actual payment periods. The SPFE provides general services for tracking the payment of invoices.
The Spanish system consists of the private exchange platforms (Plataformas Privadas de Intercambio, PPI) and the SPFE. An electronic invoice must always travel through one of these routes. A direct exchange between two businesses without a PPI or the SPFE does not meet the requirement. The Agencia Tributaria describes three models.
Choosing a private platform does not take the state out of the process. Anyone who does not use the SPFE to issue invoices must transmit a faithful copy of every invoice in UBL syntax to the state solution at the same time as the invoice is issued. The SPFE is also the mandatory repository of all electronic invoices, whether as originals or as faithful copies.
The copia fiel is not the invoice. It contains a summary of the tax information derived from the original invoice, with semantics and syntax equivalent to those of the SPFE and following the content defined in Orden HAC/1028/2026. It is always marked as a faithful copy. The original may have been issued in another admitted syntax.
Private exchange platforms carry their own obligations under Real Decreto 238/2026. These apply from 6 October 2027, twelve months after the order entered into force.
The platform must allow the addressing and the direct transmission of electronic invoices between issuer and recipient. It does not have to be invoicing software itself.
The platform must be able to transform the invoice message into all the formats set out in the rules.
Invoices issued through a PPI carry an advanced electronic signature and a unique identifier made up of the issuer's NIF, the number and series, and the date of issue.
Every PPI must interconnect with any other PPI in the Spanish system. The connection covers at least the exchange of invoices and the communication of payment statuses, and it is free of charge for both sides.
The SPFE may be used as the means of interconnection. In that case the syntax is UBL, and the receiving platform retrieves the message and transforms it into one of the admitted syntaxes where necessary. UBL is the reference syntax of the state solution because it complies with the European standard EN 16931 and is one of the syntaxes admitted under Directive 2014/55/EU.
Invoice-Portal is a certified Peppol access point and covers country-specific requirements behind a single ERP integration. For Spain this concerns the format and also the steps that follow dispatch: the faithful copy to the SPFE and the return of invoice and payment statuses. We agree the functions available at each deadline against your timetable and your classification.
Note: the Spanish system is not a Peppol network. Peppol and the Spanish requirements are to be treated separately, even though both build on UBL and EN 16931.
Test the platform free of charge for 14 days, with no installation in your ERP system.
Start free trialIt covers transactions between businesses and professionals where the recipient has the seat of its economic activity, a permanent establishment or its habitual residence in Spain, and the supply is made to that location. It applies to transactions subject to IVA, IGIC or IPSI. Supplies to private consumers and transactions with a counterpart not established in Spain are outside the obligation.
If the turnover for VAT purposes in the immediately preceding calendar year exceeded 8 million euro, the invoicing obligation applies from 6 October 2027, otherwise from 6 October 2028. Status reporting follows at the same date for legal persons, and from 6 October 2029 for natural persons and entities under the income attribution regime.
The invoice itself may travel through private platforms. Anyone who does not use the SPFE to issue invoices must, at the same time as issuing, transmit a faithful copy in UBL to the SPFE. The state solution is the mandatory repository of all electronic invoices.
The recipient reports the full payment together with the payment date and the due date to the SPFE. To the issuer it reports the commercial acceptance or rejection with its date, and the effective full payment. The complete catalogue of statuses and the technical specifications are set out in Real Decreto 238/2026 and Orden HAC/1028/2026.
The SPFE uses UBL as its reference syntax, and the faithful copy is transmitted in UBL. Original invoices may be issued in another admitted syntax, and private platforms must be able to transform the message into all the formats set out in the rules.
The German obligation concerns the issuing and receiving of structured invoices. Spain additionally requires transmission into the state system and the reporting of invoice and payment statuses. These requirements should be planned separately.
