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Spain Publishes Initial Technical Architecture for Mandatory B2B E-Invoicing

Spain’s tax authority, the Agencia Estatal de Administración Tributaria (AEAT), has published the first detailed technical and operational specifications for the country’s forthcoming mandatory B2B e-invoicing regime.

The release provides businesses, software providers, and e-invoicing platforms with the clearest view so far of how Spain’s new compliance framework is expected to operate in practice.

The implementation timetable remains unchanged:

  • 1 October 2027: Mandatory B2B e-invoicing for large businesses with an annual turnover above €8 million
  • 1 October 2028: Mandatory B2B e-invoicing for all other taxpayers

The specifications confirm that Spain will adopt a hybrid public-private model, combining private e-invoicing platforms with the government’s Public Electronic Invoicing Solution, known as the **Solución Pública de Facturación Electrónica or SPFE.

Hybrid Public-Private E-Invoicing Model Confirmed

Spain’s e-invoicing framework will allow businesses to exchange invoices through private platforms or directly through the government platform.

However, where invoices are exchanged through private platforms, those platforms will be required to simultaneously submit a faithful copy of the invoice to the SPFE. This copy must be clearly identified using a CopyIndicatorflag.

This confirms that private operators will continue to play a central role in Spain’s e-invoicing ecosystem, while the government will maintain a central repository of invoice data.

Each invoice will also need to include a unique identification code based on the supplier’s tax identification number, or NIF, together with the invoice series, invoice number, and issue date. This mechanism is intended to support automatic duplicate detection across the system.

UBL 2.5 and EN 16931 Alignment

AEAT has confirmed that Spain’s mandatory invoice syntax will be **UBL 2.5**, aligned with **EN 16931**, the European standard for electronic invoicing.

The technical architecture will require:

  • UBL 2.5 invoice syntax
  • Alignment with EN 16931:2026
  • Certificate-based authentication
  • Synchronous web service connections

Spain will use a two-layer validation model consisting of:

  • XSD validation for structural and syntax checks
  • Schematron validation** for business rule validation

Unlike some other e-invoicing regimes, Spain does not currently plan to provide a public online validation service. As a result, businesses and platforms will need to embed validation logic directly into their own systems before invoices are transmitted.

This means implementation projects will need to address not only invoice creation and exchange, but also robust pre-submission compliance checks.

Mandatory Invoice Lifecycle Reporting

The specifications also provide further detail on Spain’s invoice lifecycle reporting obligations.

Mandatory invoice status events will include:

  • Acceptance or rejection of the invoice
  • Due date information
  • Full payment date

A notable feature of the Spanish model is that silence from the recipient will be treated as acceptance. This should reduce the need for explicit confirmation messages often, but businesses will still need systems capable of tracking and reporting the required invoice status events.

These obligations go beyond basic invoice transmission and will require companies to maintain accurate invoice monitoring and workflow processes throughout the invoice lifecycle.

New Responsibilities for Platforms and Intermediaries

The documents also clarify the expected role of service providers, platforms, and intermediaries under the new regime.

Platforms will be required to:

  • Aggregate invoice traffic for their clients
  • Hold formal Powers of Attorney, known as apoderamiento
  • Automatically retrieve invoices on behalf of customers

This appears to rule out simple pass-through or messaging-only models that do not actively manage invoice exchange and retrieval.

For many providers, obtaining, maintaining, and administering customer authorizations may become as important as the technical integration itself.

Power of Attorney Becomes a Key Compliance Requirement

The AEAT specifications highlight an important distinction between invoice submission and invoice retrieval.

Invoices may be submitted either through a registered Power of Attorney, or apoderamiento, or through a social collaborator arrangement. However, automated invoice retrieval from the SPFE will require a formal Power of Attorney. Without this authorization, automated invoice collection will not be possible. For multinational groups, shared service centres and outsourced compliance providers, representation management is therefore likely to become a significant implementation workstream.

Next Legislative Milestone Expected in October 2026

The next major milestone is expected to be the publication of the relevant ministerial order in Spain’s Official State Gazette, the Boletín Oficial del Estado or BOE, anticipated on 1 October 2026.

Following publication, businesses and service providers can expect the release of further implementation materials, including:

  • Opening of the government sandbox environment
  • Developer portal documentation
  • XSD schemas
  • Schematron business rules
  • WSDL technical specifications
  • Sample message libraries

The first mandatory compliance deadline remains expected in October 2027 for large businesses, followed by the wider taxpayer population in October 2028.

Business Impact

Spain’s publication of its initial technical architecture marks an important step toward mandatory B2B e-invoicing. The framework confirms that compliance will involve more than simply generating invoices in a new electronic format.

Businesses will need to prepare for invoice validation, lifecycle reporting, representation management, platform connectivity, and automated retrieval requirements. For large taxpayers, the October 2027 deadline leaves limited time to assess current systems, select technology partners, and begin implementation planning. Service providers and intermediaries will also need to review their operating models to ensure they can meet Spain’s technical, legal, and authorization requirements under the new regime.

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

 

Country update for Spain
10 June 2026
Stay informed about the latest indirect tax developments in Spain, including regulatory changes, compliance requirements, and indirect tax guidance affecting businesses operating locally and cross-border. This page provides a structured overview of country-specific updates, such as new legislation, reporting obligations, digital tax initiatives, and implementation timelines.
These insights help tax, finance, and compliance professionals anticipate regulatory changes, adjust processes and systems, and maintain compliant operations in Spain.