Mandatory Electronic Invoicing: The Countdown Begins for Businesses.

On 5 October 2026, Order HAC/1028/2026 of 2 October, regulating the public electronic invoicing solution (hereinafter, the Order), was published in the Official State Gazette (BOE), in accordance with the provisions of Royal Decree 238/2026 of 25 March, implementing the mandatory electronic invoicing system between businesses and professionals (hereinafter, the Regulation).

Its publication is not merely a technical development. The Regulation made the entry into force of the electronic invoicing obligation conditional upon the approval of the Order. With its entry into force, the countdown officially begins, establishing the deadlines that determine when electronic invoicing will become mandatory between businesses and professionals in Spain.

The Timeline Now in Effect

The Order enters into force on the day following its publication, meaning that the calculation of the relevant deadlines began on 6 October 2026. From that date, the regulatory framework governing electronic invoicing establishes two different implementation deadlines depending on the annual turnover of each business or professional.

• Businesses and professionals with an annual turnover exceeding €8 million: the obligation will become enforceable one year later, from 6 October 2027.

• All other businesses and professionals: the obligation will become enforceable two years later, from 6 October 2028.

What Does This Mean for Businesses?

Until now, the mandatory electronic invoicing timetable was subject to a pending regulatory development. With the publication of the Order, that condition has now been fulfilled, and the implementation dates are confirmed: 6 October 2027 for businesses and professionals with annual turnover exceeding €8 million, and 6 October 2028 for all other businesses and professionals.

Accordingly, businesses should now incorporate these dates into their technological and organisational planning processes. This applies whether they choose to use the public electronic invoicing solution managed by the Spanish Tax Agency (AEAT) or a private electronic invoicing exchange platform.

However, the above timetable reflects the regulatory position as of today and should be considered without prejudice to any future amendments that may be introduced. As seen with the Verifactu system, further changes could still occur in the coming months as a result of ongoing legislative and regulatory developments in this area.