Spain's B2B e-invoicing clock finally started on 6 October: autónom@s have until October 2028

The ministerial order that Spain’s mandatory business-to-business e-invoicing regime had been waiting on was published on 5 October 2026 and entered into force the following day. Orden HAC/1028/2026, de 2 de octubre (BOE-A-2026-20587, BOE núm. 247) regulates the solución pública de facturación electrónica, the free public invoicing platform the Agencia Tributaria was tasked with building. Its entry into force on 6 October 2026 starts the countdown that had no start date until now.

Under disposición final cuarta of Real Decreto 238/2026, de 25 de marzo, the deadlines run from that date:

• 6 October 2027 – businesses and professionals whose turnover exceeded 8 million euros in the previous calendar year
• 6 October 2028 – every other business and professional in scope, which is where Spain’s autónom@s sit

Why this matters. If you invoice Spanish businesses as an autónom@, you now have a real date for the first time since the Crea y Crece law was passed in 2022: 6 October 2028. Two years is enough time that nothing needs doing this month, and it is also the reason to stop treating B2B e-invoicing as indefinitely postponed. The obligation under Article 8 bis of Real Decreto 1619/2012 applies where the recipient of the transaction is a business or professional based in Spain, so an autónom@ whose clients are all businesses is squarely in scope. Invoicing a consumer is not, and simplified invoices are excluded apart from those covered by Article 7.2.

Context. This is a separate regime from Verifactu and the two are constantly conflated. Verifactu governs the integrity of the billing record: that invoices cannot be altered without trace. Article 8 bis governs the format and transmission of the invoice itself. A business can be inside one and outside the other, and the two have always had different clocks. What changed this week is that they are being brought together: on 5 October the Ministry of Finance announced it intends to defer the remaining Verifactu obligations to October 2028 precisely so that both land on the same date, sparing small businesses two separate migrations. That deferral is announced and not yet enacted. This order, by contrast, is published and in force.

What to watch. The twelve-month tranche bites first, in October 2027, and it reaches further than its own turnover threshold suggests: once large businesses have to send structured electronic invoices, their suppliers have to be able to receive and respond to them. If your clients are large Spanish companies, the practical date for you is closer to 2027 than 2028. For the wider picture on invoicing obligations in Spain, see our guide to becoming autónomo in Spain.