Order HAC on Spain’s Public Electronic Invoicing Solution

Order HAC/1028/2026 of 2 October, issued by the Spanish Ministry of Finance, regulates the technical and functional requirements of the public electronic invoicing solution managed by the Spanish State Tax Administration Agency (AEAT), as well as the content and format requirements for electronic invoices under the EN 16931 model and UBL syntax, implementing Royal Decree 238/2026. Its objective is to specify the procedures for issuing, interconnecting, validating, retrieving and consulting electronic invoices, as well as reporting invoice status and payment information, to facilitate the implementation of mandatory B2B electronic invoicing system for businesses and professionals in Spain.

Order HAC on Spain’s Public Electronic Invoicing Solution

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Executive summary

The Order establishes the content and format requirements for electronic invoices in accordance with the EN 16931 model and UBL syntax. It also requires the simultaneous submission of a faithful copy of each invoice when private platforms are used. In addition, it regulates the procedures for issuing, interconnecting and validating electronic invoices, their unique identification and the reporting of invoice status and payment information, including rejections, actual payments and voluntary notifications of collections and non-payments. The Order further specifies the services for retrieving, consulting and downloading invoices, as well as the authentication, representation, data protection and security mechanisms required to access the public electronic invoicing solution.

The Order entered into force on 6 October 2026, marking the starting point for calculating the implementation deadlines. The public electronic invoicing solution must be available by 6 August 2027. The obligations will apply from 6 October 2027 to businesses and professionals with an annual turnover exceeding €8 million as well as to private platforms in respect of the requirements applicable to them, and from 6 October 2028 to all other businesses and professionals.

Main content

Order HAC/1028/2026 is structured around four main areas:

• Content and technical requirements for electronic invoices. The Order establishes the use of the EN 16931 model and UBL syntax for invoices issued or interconnected through the public solution. It also establishes requirements for invoice content and identification, as well as the simultaneous submission of a faithful copy of each invoice where private platforms are used.
• Procedures for issuing, interconnecting, and validating invoices. The Order governs the procedures for issuing and interconnecting invoices, the syntactic and semantic validation checks to be performed, the assignment of a unique invoice identification code, and the handling of rejections, duplicate invoices and technical incidents.
• Invoice status and payment reporting. The Order specifies the obligations and procedures for reporting rejections and payments, submitting voluntary notifications of collections and non-payments, and validating and cancelling messages.
• Invoice retrieval, consultation, and access to the public solution. The Order establishes services for the automated retrieval, consultation and downloading of invoices and their status, as well as requirements for authentication, representation, data protection and security.

Download the technical note on the Order HAC on Spain’s Public Electronic Invoicing Solution (also available in Spanish).