Spain’s Orden HAC/1028/2026, published in the Boletín Oficial del Estado on 5 October 2026 and entering into force on 6 October 2026, closes the last regulatory gap in the country’s mandatory B2B e-invoicing project. Compliance deadlines are now official and legally binding (Agencia Tributaria, 7 October 2026).
Five Years of Legislation, Finally Concrete
Mandatory B2B electronic invoicing in Spain has been built up through a long chain of regulation. The Ley 18/2022 (Ley Crea y Crece) established the principle. The Real Decreto 238/2026 of 25 March 2026 defined the technical architecture. What was still missing was the ministerial order that would set the practical rules for the public platform and start the compliance clock.
That order is now in place. Signed on 2 October 2026, published on 5 October, and in force from 6 October, the Orden HAC/1028/2026 completes the regulatory framework. In parallel, the AEAT is opening access to the Solución Pública de Facturación Electrónica (SPFE) for technical testing (ibid.).
What the Orden Changes in Practice for CIOs and CFOs
Two hard deadlines. Spanish businesses and professionals whose annual transaction volume exceeds €8 million must issue and receive compliant electronic invoices — and report payment status data to the SPFE — by 6 October 2027. All others have until 6 October 2028 (Atecna, 5 October 2026). A third threshold, 6 October 2029, extends the payment-status reporting obligation to individuals operating under a special VAT regime.
One planning detail to flag: the reference date is 6 October, not 1 October as indicated in the draft order published in April 2026. The five-day shift does not change project timelines in practice, but the BOE date is the one that matters contractually.
The SPFE: free and UBL 2.5 only. The AEAT’s public platform is available at no cost. It operates exclusively with UBL 2.5, aligned with the European standard EN 16931. Teams still running Facturae connectors (the legacy format used for Spanish public-sector invoicing) will need to update their XML pipelines to communicate with the SPFE. Certified private platforms may accept Facturae, UBL 2.1, CII or EDIFACT. In all cases, a faithful copy of every invoice must reach the SPFE — even when the commercial transaction runs through a private platform (ibid.).
The receiver obligation: frequently overlooked in ERP projects. The recipient of an electronic invoice must report three data points to the SPFE: commercial rejection, actual full payment date, and payment due date. This requirement is routinely underestimated in projects that focus solely on outbound invoicing. Compliance covers inbound flows too, and the accounts payable module must be updated accordingly.
The test environment is open now. The AEAT is opening test access at the same time the order enters into force. This is the window to use immediately — connect your ERP to the SPFE before calendar pressure builds.
What to Watch
The overlap with VeriFactu. Both obligations are cumulative. An ERP that is VeriFactu-compliant (deadline: 1 January 2027 for companies subject to Impuesto sobre Sociedades, 1 July 2027 for autónomos) does not automatically meet the format and transmission requirements imposed by the Orden for B2B invoicing. A project addressing only one of these two tracks will be incomplete in production.
ERP certification status. Vendors active in Spain — SAP, Microsoft Business Central, Sage, Cegid, Holded, A3ERP — are at different stages of SPFE readiness. Following Business Central’s general availability of VeriFactu support in September 2026, the next milestone is SPFE certification for the main platforms. Now is the right moment to ask your vendor for their certification roadmap and avoid a last-minute dependency on a critical patch.
Foreign group subsidiaries in Spain. For a CIO at a French, Belgian or German group managing an Iberian subsidiary, the Orden HAC/1028/2026 confirms that this can no longer be delegated to the local IT provider. The subsidiary’s systems must be certified, connected to the SPFE, and any intercompany invoicing flows directed at Spain must be updated to comply.
For the full regulatory picture, read our analysis of the Real Decreto 238/2026 on Spanish B2B e-invoicing, our breakdown of the SPFE as defined by the AEAT in September 2026, and our overview of Spanish ERP systems facing SII, TicketBAI and fiscal compliance.
