Spain Publishes Technical Rules for Public E-Invoicing Platform

Spain’s Tax Agency (Agencia Tributaria), operating under the Ministry of Finance, opened a draft Ministerial Order for public consultation on 17 April 2026, setting out the technical and functional framework for the public e-invoicing platform (Solución Pública de Facturación Electrónica) required under Royal Decree 238/2026 of 25 March 2026, which introduced mandatory B2B electronic invoicing in Spain.

The draft order specifies the requirements for the public platform to be developed and operated by the State Tax Administration Agency (AEAT). Use of the platform will be free of charge for all businesses and professionals.

UBL and EN16931 Standard Required

All electronic invoices issued or transmitted through the public platform must conform to the EN16931 semantic data model defined by the European Committee for Standardization, using UBL (Universal Business Language) syntax. Businesses that choose to use private platforms instead of the public solution will still be required to simultaneously submit a faithful electronic copy of each invoice in UBL format to the public platform at the time of issuance. Those using the public platform directly are exempt from this copy-submission requirement.

Unique Invoice Code

Each electronic invoice will be assigned a unique identifier derived from the concatenation of the issuer’s tax identification number (NIF), invoice number, series, and date of issue.

Payment Notification Obligations

Invoice recipients will be required to notify the public platform of full payment, including the payment date and due date, as well as any rejection of the invoice. Issuers may voluntarily report collection or non-payment information to the platform. This mechanism is designed to monitor commercial payment timelines and calculate average payment periods as part of Spain’s efforts to combat late payments.

Authentication

Access to the platform will require a qualified electronic certificate or authentication via Spain’s Cl@ve system. The platform may also be accessed by an authorized representative acting on behalf of a business or professional.

Technical Disruption Provision

In the event of a technical outage preventing use of the platform, invoices and payment notifications may be submitted within four days following the resolution of the disruption.

Entry into Force

The Ministerial Order is set to enter into force on 1 October 2026. The public platform must be made available to businesses and professionals at least two months before that date.