Spain’s tax authority (AEAT) published technical details of the Solución Pública de Facturación Electrónica (SPFE) in mid-September 2026: UBL 2.5 format aligned with European standard EN 16931, four core capabilities, and a test environment opening in October 2026. Two dates are now fixed in the ERP calendar of every business operating in Spain: 1 October 2027 for companies with annual revenue above €8 million, 1 October 2028 for all others (atecna.com, 15 September 2026).
Context: SPFE and VeriFactu — Two Different Roles in the Same Ecosystem
The SPFE sits within the regulatory framework established by Real Decreto 238/2026 and the Ley Crea y Crece (Ley 18/2022). For IT or finance leaders who have followed this topic for years, one confusion persists: what is the difference between VeriFactu and the SPFE?
Both coexist within the same system, with clearly distinct roles. VeriFactu defines the technical integrity requirements for invoicing software: tamper-evident records, hash chaining, real-time transmission to the AEAT. The SPFE is the public infrastructure for exchanging and registering B2B invoices: issuing, receiving, tracking payment status, and storing certified copies (Cegid, official blog). VeriFactu governs software security; the SPFE governs the invoice exchange channel.
What the SPFE Means in Practice for IT and Finance Leaders
UBL 2.5: the only format accepted by the public platform. The SPFE operates exclusively in UBL 2.5 (EN 16931 compliant). The Facturae format — historically used for electronic invoicing with Spanish public administrations — is not accepted by the SPFE. It remains valid only for exchanges between private platforms under Royal Decree 238/2026 (ClearTax, SPFE documentation). For ERP teams, this means updating XML invoice generation connectors if the current system produces Facturae output.
A hybrid model — but with a mandatory certified copy. Spain has adopted an open model: companies may use the SPFE directly, route through one or more certified private platforms, or combine both. However, regardless of the path chosen, a certified copy (copia fiel) of each invoice must reach the SPFE. This deposit obligation applies even when the commercial transaction flows through a private platform (ibid.).
Four capabilities, including free access for SMEs. The AEAT platform provides four functions: individual invoice issuance (a free tool, particularly useful for micro-businesses), invoice status consultation and communication (commercial rejection, payment confirmation), an interconnection hub between businesses and platforms, and a repository that receives originals or certified copies (atecna.com). For SMEs without an ERP or with a system not yet certified, the SPFE provides a no-cost baseline entry point.
Important: AEAT does not handle your archiving obligations. A detail frequently misread in initial reviews of the regulation: the SPFE does not replace the legal obligation to retain invoices. Each business remains responsible for archiving its own invoices and exchange records. The public platform receives invoices — it does not preserve them on behalf of the issuer.
Direct API connection is possible, but technical. Companies can connect their systems directly to the SPFE without going through a software vendor or a dematerialisation service provider, provided they meet the identification and technical development requirements set by the AEAT (ibid.). For SMEs without in-house technical resources, integration via a certified ERP vendor will remain the simplest route.
What to Watch Starting October 2026
The AEAT plans to publish the ministerial order and open the test environment in October 2026. This is the window IT leaders cannot afford to miss: validate the connection between the production ERP and the SPFE before compliance deadlines become an operational constraint.
For companies above €8M in revenue, the 1 October 2027 deadline leaves exactly twelve months to certify, integrate, and test. For others, the 1 October 2028 deadline provides two years — but ERP projects with regulatory components typically require 6 to 18 months of preparation. Initiating the conversation with your ERP vendor as soon as the ministerial order is published is the right reflex.
A third threshold deserves attention: from 1 October 2029, the mandatory communication of payment status extends to sole traders and entities with annual revenue at or below €8M (ClearTax).
For deeper regulatory context, read our analysis of Spain’s B2B Electronic Invoicing Mandate: RD 238/2026 Framework and Timelines, our guide to Spanish ERP: Holded, Factorial, SII and TicketBAI, and our article on Business Central’s native VeriFactu support reaching GA in September 2026.
