Spain sets the dates for mandatory B2B e-invoicing: October 2027 and 2028

Spain has published the order that sets up its public e-invoicing platform, and it fixes the clock for mandatory B2B invoicing. Businesses with turnover above €8 million have until 6 October 2027. Everyone else has until 6 October 2028.

What was published

On 5 October 2026, the Spanish Official State Gazette (BOE) published Order HAC/1028/2026, which regulates the public e-invoicing solution (solución pública de facturación electrónica). The order enters into force the day after publication, on 6 October 2026.

The deadlines themselves sit in Royal Decree 238/2026, published on 31 March 2026. Its final provisions count both deadlines from the order's entry into force:

• Turnover above €8 million: 12 months, so 6 October 2027.
• All other businesses and professionals: 24 months, so 6 October 2028.

Private invoice platforms have a 12-month deadline from the same date. Public-sector subcontractors that submit invoices through the public procurement register have 24 months.

What this means for software teams

If your product issues invoices to Spanish businesses, check two things now:

1. Which tier your customers fall into. Turnover is the deciding factor, so a customer near €8 million may move from the 2028 group to the 2027 group.
2. Whether your invoices can be delivered through the public platform. The order sets out the technical rules for sending and receiving through the public solution. Your integration should be able to create, transmit, and track invoice status without a manual step.

Start with the test environment rather than waiting for the deadline. Build the send and status-tracking path first, then add error handling for rejected documents.

Read the primary text

• The order: BOE-A-2026-20587, published 5 October 2026.
• The decree's final provisions: Royal Decree 238/2026, on the BOE website.

If you need the exact turnover test or the subcontractor rules, read the decree's final provisions directly rather than a summary.

Next step

Read the developer documentation for the request and status model, then test your Spanish invoice flow in the sandbox before the 2027 tier starts.