Treasury regulates the public solution for mandatory electronic invoicing between companies

The Ministry of Finance has approved Order HAC/1028/2026, of October 2, which regulates the public electronic invoicing solution provided for in Royal Decree 238/2026, of March 25. The regulation is published in the Official State Gazette number 247, of October 5, 2026, with the reference BOE-A-2026-20587. Its entry into force, the day after publication, begins the countdown for the deadlines for mandatory electronic invoicing between entrepreneurs and professionals.

The order develops the third final provision of Royal Decree 238/2026, which in turn deploys article 2 bis of Law 56/2007 and the twenty-first additional provision introduced by Law 7/2024. The stated objective is to reduce commercial delinquency through reliable information on effective payment terms, in line with Law 18/2022, on the creation and growth of companies.

The Spanish electronic invoice system will combine private exchange platforms with the public solution, whose development and management correspond to the State Tax Administration Agency (AEAT). The order consists of 11 articles, two additional provisions, one final provision, and two annexes, and was signed in Madrid on October 2, 2026, by the Minister of Finance, Arcadi España García.

Obligations for freelancers and SMEs

• All entrepreneurs and professionals must issue, send, and receive electronic invoices in their commercial relations with other entrepreneurs and professionals.
• Those who do not use the public solution must simultaneously send, upon issuance, a faithful electronic copy of each invoice in UBL syntax.
• The recipient must electronically communicate the rejection of the invoice, the date of full effective payment, and the expiration date of the payment term.
• The issuer may voluntarily report the collection or non-payment.

Application deadlines

Entry into force occurs the day after publication, and with it begins the countdown for the deadlines of the eighth final provision of Law 18/2022 and the first to third transitional provisions and the fourth final provision of Royal Decree 238/2026:

• Twelve months for entrepreneurs and professionals whose volume of operations exceeded 8 million euros in the immediately preceding calendar year.
• Twenty-four months for the remaining entrepreneurs and professionals.
• Twelve months for private platforms to send faithful copies and interconnect with each other.
• Twenty-four months for subcontractors who currently submit their invoices through the FACeB2B registry.

The public solution must be available on the electronic office of the AEAT at least two months before its first effective application.

Technical requirements and free access

Electronic invoices shall comply with the EN16931 semantic model of the European Committee for Standardization under the UBL syntax. Each invoice will have a unique code formed by the concatenation of the issuer’s NIF, the series, the number, and the date of issuance.

Access to the public solution and its various uses shall be free of charge for users. Authentication and identification will be carried out using valid electronic certificates and, in the case of forms, also via Cl@ve. Services will be provided via web service and via form; when a technical incident prevents their use for more than 24 hours, submission may be carried out within the four business days following its resolution.

The regulation activates the calendar for mandatory electronic invoicing between companies in Spain and turns the AEAT into a universal repository for electronic invoices issued, sent, or received. For freelancers and SMEs, free access to the public solution seeks to avoid the cost of private platforms, although phased compliance will require them to adapt their systems within the scheduled deadlines.

Source: Official State Gazette, no. 247, October 5, 2026, Sec. I. General Provisions, page 129349 (official reference: BOE-A-2026-20587).