The publication of Order HAC/1028/2026 completes the regulatory framework for mandatory electronic invoicing between businesses and professionals in Spain, establishing a phased implementation timetable starting in October 2027.
On 5 October 2026, Order HAC/1028/2026 of 2 October was published in the Spanish Official State Gazette (BOE), regulating the Public Electronic Invoicing Solution and completing the regulatory framework for this new obligation, originally introduced by Law 18/2022 on the Creation and Growth of Companies (Crea y Crece Law) and further developed by Royal Decree 238/2026.
The new regulations represent a significant change in invoicing procedures for businesses and professionals, who will need to adapt their systems to issue and receive electronic invoices in their commercial transactions.
1. Who is affected?
Electronic invoicing will generally be mandatory for transactions between businesses and professionals (B2B transactions), regardless of whether they operate as individuals or legal entities.
The obligation will therefore not be limited to large companies but will progressively extend to SMEs and self-employed professionals.
2. Implementation timetable
The obligation will be introduced in stages, depending on the taxpayer’s turnover, calculated in accordance with Article 121 of the Spanish VAT Law.
| Taxpayers concerned | Implementation date |
|---|---|
| Businesses and professionals with annual turnover exceeding €8 million | 6 October 2027 |
| All other businesses and professionals | 6 October 2028 |
| Obligation to report invoice statuses for individuals with turnover below €8 million | 6 October 2029 |
These dates are calculated from the entry into force of the Ministerial Order on 6 October 2026.
3. How will electronic invoicing work?
The regulations provide for the use of private electronic invoicing platforms alongside a Public Electronic Invoicing Solution, which will:
- Enable the issuance and generation of electronic invoices.
- Facilitate interoperability between different private invoicing platforms.
- Operate as a universal repository for electronic invoices, receiving an identical copy of invoices issued.
In addition, the new system introduces reporting obligations concerning certain invoice statuses, aimed at improving transaction traceability and monitoring commercial payments.
4. Electronic invoicing and Veri*factu: two separate obligations
It is important not to confuse mandatory electronic invoicing with the regulations commonly known as Veri*factu.
While mandatory electronic invoicing primarily governs the issuance, receipt and exchange of electronic invoices between businesses and professionals, Veri*factu establishes the technical requirements that certain invoicing software systems must meet to ensure the integrity, preservation and traceability of invoicing records.
Furthermore, their respective scopes of application do not necessarily coincide. In particular, companies subject to the Immediate Supply of Information (SII) system are excluded from the scope of the invoicing software regulations, but this does not automatically exempt them from the general B2B electronic invoicing obligation.
The deadline for adapting to Veri*factu was postponed until 2027 under Royal Decree-Law 15/2025, without prejudice to any further regulatory amendments.
5. What should businesses do now?
Although mandatory electronic invoicing will begin to apply in October 2027, businesses and professionals should start reviewing their invoicing procedures and the capabilities of their existing software systems.
In particular, they should assess whether their current systems are compatible with the new requirements for issuing, receiving and exchanging electronic invoices.
In summary, the publication of this Ministerial Order provides greater certainty regarding the implementation timetable and marks the beginning of the technological and administrative adaptation process for businesses and professionals ahead of the introduction of mandatory electronic invoicing in Spain.