Electronic invoicing now has a date

If you were told that electronic invoicing between businesses in Spain still had no date, there is now a rule that starts the clock. Order HAC/1028/2026, published on 5 October and effective from the 6th, governs the Spanish Tax Agency's public solution. That tool must be available at least two months before the first effective application.

This is the published timetable as of 10 October 2026. To work out what applies to you, separate invoice exchange from the rules your software has to meet.

Who it covers

Royal Decree 238/2026 covers invoiceable transactions with business or professional recipients established in Spain under its Article 3. It excludes certain simplified invoices; it does not set the general timetable for consumer invoices.

The deadline: twelve months if the previous calendar year's volume of transactions exceeds eight million euros under Article 121 of Spain's VAT Law; twenty-four for the rest. General dates: 6 October 2027 and 6 October 2028, respectively.

It is not equivalent to VERI*FACTU

The consolidated version of Royal Decree 1007/2023 governs computerised invoicing systems: integrity, retention and traceability of their records. VERI*FACTU is a mode that sends records to the AEAT, Spain's Tax Agency; not every mode requires that transmission.

For those covered by Article 3.1.a — Corporate Income Tax taxpayers — systems must be adapted before 1 January 2027; for the other affected taxpayers, before 1 July 2027. There are exclusions, including taxpayers keeping their books through Spain's SII system, and the territorial scope needs checking.

Electronic invoicing requires a structured format; a PDF is not enough. Ask the provider for specific evidence of invoice exchange.

The recurring work

Article 10 requires reporting acceptance/rejection and full payment, with dates, to the issuer within four calendar days, excluding Saturdays, Sundays and national public holidays. Article 12 governs payment/rejection reporting to the public solution; payment has that deadline from its effective date.

For status reporting, individuals and entities under Spain's income attribution regime with a volume of transactions of up to eight million have twelve additional months; this does not cover every small company.

If someone currently checks the bank and records payments by hand, it is worth reviewing how that information will reach the system. An invoice can be issued correctly and still need follow-up afterwards.

What to ask this week

I would send the software provider three questions in writing:

• Which requirements of the invoicing systems regulations your current version meets, and which mode it offers.
• When you will be able to issue and receive structured electronic invoices, and which platforms or public solution have been used to test interoperability.
• How statuses and payments will be reported, what you will need to enter yourself and how failed transmissions will be detected.

Then check with your tax adviser which transactions and dates affect you. Keep the answers and set a date to review them: a pending plan needs follow-up too.

There is no need to buy on the strength of a headline or wait until the final month. What matters now is identifying what your provider already covers and what depends on changing how you record invoices and their payments.