Spain Launches Public Consultation on B2B Electronic Invoicing Solution

Spain has initiated a significant public consultation (17 April–8 May 2026) concerning the Draft Order regulating a public B2B electronic invoicing solution.

This legislation aims to streamline invoicing practices for businesses and professionals, implementing essential features of the mandatory e-invoicing system outlined in the Third Final Provision of Royal Decree 238/2026. The public platform is expected to enhance invoice issuance, interconnection, and payment status reporting, marking a notable shift in the country’s invoicing framework, which will ultimately come into effect on 1 October 2026.

Executive Summary

The Draft Order, developed by the Agencia Estatal de Administración Tributaria (AEAT) or Spanish Tax Agency, seeks to introduce a public electronic invoicing platform aimed at ensuring mandatory electronic transactions between businesses. Its core objectives are to define service characteristics, establish technical requirements for e-invoices, and streamline communication related to payments. Notably, this legislation addresses the pervasive issue of commercial late payments by allowing real-time tracking of invoice statuses. The solution will be freely available to users and will serve as the primary repository for all B2B invoices, with a gradual rollout commencing in October 2027 for larger businesses and extending to others by October 2028.

Background and Legislative Context

This Draft Order is a continuation of efforts to modernize Spain's business landscape while simplifying invoicing practices. It evolves from various legislative initiatives:

• Law 18/2022: Introduced mandatory B2B electronic invoicing and focused on providing reliable payment period information to combat late payments.
• Royal Decree 238/2026: Established the mandatory framework for e-invoicing and mandated the development of a public solution by the AEAT.
• Royal Decree 1619/2012: Served as the original invoicing regulatory framework, which is now being updated to accommodate these advancements.

Objectives of the Draft Order

The Draft Order aims to:

1. Define the characteristics and functionalities of the public e-invoicing solution.
2. Establish technical standards for electronic invoices, including unique identification codes, payment status messages, and faithful copies.
3. Specify authentication and identification processes for accessing the solution.

Key Features of the Public Electronic Invoicing Solution

The AEAT will oversee the management of this solution, which includes:

• Universal Repository: A mandated repository for all electronic invoices issued or received.
• Interconnection Hub: A platform that connects both public and private e-invoicing solutions, ensuring seamless interoperability.
• Payment Monitoring: An innovative feature intended to track payment statuses to prevent late payments.
• No Cost for Users: Access to the platform is provided free of charge.

Obligations for Businesses and Professionals

Under the new legislation, businesses and professionals must:

1. Issue, send, and receive electronic invoices in all B2B transactions.
2. Provide invoice status updates and payment confirmations.
3. Optionally utilize the public platform or private service providers for e-invoicing solutions.
4. Send faithful copies of e-invoices to the public platform if utilizing private platforms

Implementation Timeline

The Draft Order outlines a phased implementation schedule:

• October 1, 2026: Date of enactment for the Order.
• October 1, 2027: Mandatory e-invoicing for businesses with an annual turnover exceeding €8 million.
• October 1, 2028: Extension of mandates to other businesses.
• October 1, 2029: Introduction of payment status communication obligations for individuals and smaller entities.

Impact Analysis

While the Draft Order doesn't introduce new administrative burdens, it is expected to streamline compliance and improve efficiency in invoicing processes. Financial implications were previously evaluated during the Royal Decree 238/2026 assessment, indicating a comprehensive fiscal strategy.

Regulatory Principles and Data Protection

The Draft Order adheres to essential regulatory principles, ensuring transparency, efficiency, and compliance with data protection laws such as the General Data Protection Regulation (EU 2016/679) and Spain’s Organic Law 3/2018.

Conclusion

Spain’s initiative to regulate B2B electronic invoicing through a public consultation marks an essential step toward modernizing commercial transactions and promoting timely payments. The draft order aims to enhance business operations and strives to build a robust economic environment that mitigates the long-standing issue of late payments, ultimately benefiting businesses and consumers alike. The public is invited to contribute feedback until 8 May 2026, enabling a comprehensive stakeholder engagement process in shaping this significant legislation.

How Can KGT Support You?

KGT has created an SAP-integrated e-invoicing add-on solution for Spain, featuring outbound and inbound functionalities to meet tax reporting requirements. This add-on includes a data extractor and a cockpit for generating periodic electronic invoices in the legal format and controls before submission. When SAP DRC launched the Spanish e-invoicing solution as part of its e-document offerings, KGT emerged as a leading consultancy firm for SAP DRC and tax services. Recognized as an SAP DRC partner for Spanish e-invoicing services, KGT is one of SAP's recommended implementation partners for this solution. We provide comprehensive support, including installation, configuration, customization, and training, to help you maximize the long-term value of your SAP DRC investment.

KGT is an SAP partner for PE services and an SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at: https://partnerfinder.sap.com/profile/0001925409