Spain's tax authority confirms UBL 2.5 for its public B2B e-invoicing platform
Spain's tax authority confirmed UBL 2.5 for its public e-invoicing platform. The final Ministerial Order is expected in October 2026. The first B2B obligations start 12 months after it enters into force.
Spain’s Tax Authority (AEAT) held a webinar on 10 September 2026 on the country’s upcoming B2B e-invoicing obligation. The authority expects the Ministerial Order on the public e-invoicing platform (SPFE) to enter into force in October 2026. The SPFE will use UBL 2.5, aligned with EN 16931.
Spain’s Tax Authority (AEAT) gave new technical details on the mandatory B2B e-invoicing framework during a webinar on 10 September 2026. The details follow Royal Decree 238/2026 and a draft Ministerial Order. The final order has not yet been published.
Timeline and legal status
October 2026 is not the start of the mandate. It is the target for the Ministerial Order, and the order starts the legal countdown.
Royal Decree 238/2026 was published in the Official State Gazette (BOE) on 31 March 2026. According to the AEAT, its application depends on the entry into force of the Ministerial Order regulating the public solution:
- Businesses with turnover above 8 million euro in the previous calendar year must comply 12 months after the order enters into force.
- All other businesses and professionals must comply 24 months after the order enters into force.
The AEAT said during the webinar that the Ministerial Order is expected to enter into force during October 2026. Official documentation still names 1 October 2026 as the expected date. The authority acknowledged that publication may face a slight delay.
Format of the public platform
Spain will operate a hybrid e-invoicing model. It combines private platforms with the Public Electronic Invoicing Solution (SPFE) managed by the AEAT. The SPFE will use UBL 2.5, the latest version of the Universal Business Language standard, approved by OASIS in August 2026. This aligns with the EN 16931 semantic model.
The choice of UBL 2.5 means private e-invoicing platforms may need to convert invoices exchanged in other formats into the SPFE’s required format. This is most relevant for invoices exchanged using Peppol BIS Billing 3.0, which is based on UBL 2.1 and EN 16931:2017.
Technical capabilities and next steps
The SPFE will support invoice lifecycle reporting, including acceptance, rejection, and payment-related statuses. The platform will run validation controls based on UBL, EN 16931, and AEAT-specific rules.
The webinar did not address the formats and specifications for exchanges between private platforms. Further guidance is expected, notably in light of the recently published EN 16931:2026 and UBL 2.5.
The next step is publication of the final Ministerial Order. Detailed technical specifications and a testing environment should follow, both expected from October 2026.
The Spanish Senate also approved a non-binding motion on Spain’s digital reporting systems. It calls on the Government to progressively align VERI*FACTU, SII, and mandatory B2B e-invoicing into a unified framework. That framework should be compatible with the EU’s VAT in the Digital Age (ViDA) requirements.