Following the recent publication of Royal Decree 238/2026 and of a draft Ministerial Order that specifically describes how the public solution “SPFE” (Solución Pública de Facturación Electrónica) intends to operate under the mandate, the Spanish Tax Authority (AEAT) just released two new documents [↗︎] aiming at sharing the role, functionalities and technical features of the SPFE:
- The first document, called “Ministerial Order Project for the Public Electronic Invoicing Solution” focuses on business rules, invoice lifecycle, and functional workflows
- The second document, called “Public Electronic Invoicing Solution (SPFE)” focuses on technical and IT infrastructure specifications
For context, Spain has opted for a hybrid model where companies will be able to use either a private platform or the SPFE for transmitting and receiving e-invoices.
As notably indicated in both technical publications, the SPFE will support the upcoming EN 16931:2026 standard based on the forthcoming XML UBL 2.5 syntax, which is currently being finalized for official publication.
Project for the Public Electronic Invoicing Solution
Download link: Proyecto de OM Solución Pública de Facturación Electrónica [↗︎]
- Implementation Timeline: The document reinforces the implementation timeline published in April, confirming the phased rollout schedule following the mandate’s entry into force:
- October 2027: Large Companies with an annual turnover exceeding €8M must be fully compliant (12 months post-entry into force of the Order).
- October 2028: Smaller Businesses and Independent Professionals must comply with the mandate (24 months post-entry into force of the Order).
- October 2029: Self-employed individuals with a turnover under €8M must begin reporting mandatory invoice statuses – specific relief period confirmed
- Governance and Role: description of how the SPFE receives, validates the syntactic and semantic format of the UBL e-invoices, and manages their distribution to recipients
- Invoice Status Management (Lifecycle / Ciclo de vida): mandatory and optional statuses of an e-invoice
- Transmission and Access Methods: submission mechanisms for businesses (notably via web forms for small structures or automated flows/APIs for larger volumes) and defines how the centralized business directory (“Directorio de empresas”) should be organized to ensure accurate invoice routing
- Interoperability within the Hybrid Model: it outlines how the SPFE will interact with private platforms to exchange both e-invoices and their corresponding statuses
Technical aspects of the Public Electronic Invoicing Solution (SPFE)
Download link: Public Electronic Invoicing Solution (SPFE) [↗︎]
- API and Connectivity Specifications: secure protocols (REST APIs, AS4, web services) for machine-to-machine (M2M) connection with the public portal (SPFE).
- Security and Authentication: mandatory frameworks, including electronic certificates and digital signatures, to secure transmissions and verify platform identities.
- Data Schemas and Message Formats: description of the strict XML structures and validation syntax required for both e-invoices and their tracking message envelopes.
- Testing and Onboarding Environment: a sandbox environment (“entorno de pruebas”) will be available for software developers to test and validate integration before go-live. This environment will be available well in advance, but not before October 1st, 2026 (date the ministerial order should be published)
Expected Additional Technical Documentation
Several additional technical documents are also expected to be published prior to the deployment of SPFE, on the Software Developers Portal [↗︎] (“Portal de Entidades Desarrolladoras”):
- Service catalogue for companies and platforms
- Submission standards
- Authentication and representation
- Applicable limitations
- Error list
- WSDL for accessing services
- XSD schemas for custom extensions and references to OASIS (UBL)
- Validation documents (schematron)
- Illustrative examples of different messages:
- Electronic invoice/certified copy
- Payment confirmation/rejection, cancellation
