Spain's B2B e-Invoicing Mandate and the Public e-Invoicing Solution (SPFE)
What the Tax Agency (AEAT) confirmed on 10 September 2026, what it means for companies running SAP, and how to be ready for 1 October 2027.
Client briefing · September 2026 · CFOs, Finance, PMs
Download Full Briefing (PDF, EN/ES)Oct 2026
Order published + AEAT test environment
> 8M€
Mandatory from 1 Oct 2027 for companies above this turnover
1 oct 2028
All other businesses and professionals
100%
of domestic B2B invoices will reach the AEAT
Key takeaway for finance leaders: connecting SAP directly to the SPFE avoids platform fees, but your company then owns every obligation: correct invoices, sending, statuses, payment reporting and its own archive — the SPFE is not a storage system.
Why This Law Exists
Law 18/2022 'Crea y Crece' made electronic invoicing mandatory between Spanish businesses. Its main goal is not tax collection but reducing late payment: to check payment terms, the State needs to see each invoice and whether it was accepted, rejected and paid.
Royal Decree 238/2026 designed the Spanish system: companies can use private e-invoicing platforms or the public solution run by the AEAT, or both. It also set the formats and the statuses to report. The ministerial order is the last piece: it defines how the SPFE works and switches the obligations on.
Law 18/2022 approved
RD 238/2026 published (in force 20 Apr)
1st AEAT developer seminar
EU notification procedure closed
2nd seminar: final order text and web services
Order published; test environment opens
In Scope
Invoices between businesses and professionals where the issuer or the customer is established in Spain. Both sides: issuing and receiving invoices, plus reporting payments.
Out of Scope
Simplified invoices (tickets), certain gas and electricity operations, airline invoice clearing, and operations authorised by the Ministry of Economy. Special rules apply for the Basque Country and Navarre.
Near real-time reporting of VAT invoice records (large companies). Same invoices, same numbers and dates — must stay consistent with Crea y Crece.
Anti-fraud requirements for invoicing software (for companies not in SII). The SPFE free tool evolves from it; design both flows together.
The full e-invoice exchanged B2B, plus acceptance, rejection and payment statuses. New obligation — affects billing, accounts payable and treasury.
Cross-border B2B digital reporting from 1 July 2030. Next wave — a good design now avoids rework later.
The Mixed Model, Explained
Companies never send invoices directly to each other. Every invoice travels through a private platform or through the SPFE, and the AEAT always ends up with it, together with its status and payment date.
Invoices typed one by one on the AEAT website — for very low volumes.
SAP sends invoices directly by web service; customers download them from the SPFE.
A provider delivers the invoice to your customer, in its preferred format.
A Common Misunderstanding
'For software users this is transparent.' True if you buy packaged software. But a company that runs and adapts its own SAP and connects directly becomes responsible for everything a platform would otherwise do.
Unique Invoice ID
Each invoice is identified by series + number + issue date + issuer tax ID. Two invoices can never share it — numbering must be unique across all your systems.
About the SPFE
The Solución Pública de Factura Electrónica is the AEAT's platform. It is intentionally simple — 'it is not an ERP' — but its role as repository is mandatory for every company.
Free Invoicing Tool
Web form to create invoices one at a time, download PDF and XML.
Status & Payment Management
Report acceptance, rejection, payment, collection and non-payment.
Interconnection
Exchange between companies without a platform ('last resort'). The SPFE does not push invoices: the customer must collect them.
Universal Repository
Holds every original and true copy. Invoices issued outside the SPFE must be copied there immediately.
Three Quality Checks
1. Format (UBL 2.5) · 2. European content rules (EN 16931) · 3. AEAT business rules. The AEAT asks everyone to check before sending.
What the SPFE Is Not
Not a backup or archive: keep your own evidence. Not an ERP: no approvals, workflows or posting. No attachments embedded in invoices (links allowed).
Requirements
What the order asks for, translated into business requirements and the team that typically owns each one.
Every invoice meets the Spanish profile (Annex I) and passes the three checks.
Unique series and numbers across all companies, systems and branches.
Invoices (or true copies) sent immediately; receipt stored for each one.
Supplier invoices collected from the SPFE regularly and routed to accounts payable.
Rejections and full payments reported with dates.
Valid company certificate and powers of attorney, safely stored.
If the SPFE is down for 24 h, send within the next 4 business days — and keep evidence.
Own archive of invoices, receipts and statuses for the full legal period.
What Changes in the Invoice Itself
Corrective invoices: type and corrected amounts follow the European standard. Self-billing & third parties: specific codes when the customer, or an outsourced provider, issues the invoice. Tax identification: clear rules for seller and buyer tax IDs. VAT categories: new handling for travel agencies, second-hand goods, VAT groups and equivalence surcharge. Special taxes & charges: excise duties, registration tax, pass-through expenses and withholdings have their own place. Cash invoices: if already paid, the customer does not need to report payment.
State & Payment Management
Every invoice starts as Accepted. If the customer does nothing, it stays accepted. From there, the customer must report rejections and payments; the supplier may report collections and non-payments.
Rejection (commercial, or 'not related to our business') and payment (actual date and legal due date). Also tell the supplier directly whether the invoice is accepted or rejected.
Collection (full amount) and non-payment. New: flag when the invoice was collected through factoring, confirming or discounting.
No partial payments: 'paid' always means the full amount. No double statuses: a paid invoice cannot be paid again. If customer and supplier disagree, the SPFE records both — it is resolved between them.
Payment reporting for individuals and income-attribution entities is deferred to 2029; their e-invoicing obligation still starts in 2028.
Impact on SAP ERPs
SAP Document and Reporting Compliance (DRC) is SAP's standard solution for electronic documents and statutory reports. It runs inside S/4HANA, uses SAP Fiori apps, and connects to authorities through SAP Business Technology Platform (BTP). Many Spanish SAP customers already use it for SII and VAT returns.
One Monitor
The eDocument Cockpit shows every invoice with a traffic-light status, the XML and PDF, and a link to the accounting document.
Automation
eDocuments are created when the invoice is posted and can be sent in scheduled background jobs; users only handle exceptions.
Reconciliation
Consistency checks compare SAP with the authority's records (existence, status, content) — already delivered for Spain.
Archiving
Standard eDocument archiving with retention rules — covering that 'the SPFE is not a backup'.
Statutory Reporting
The same framework runs VAT returns and other declarations with a compliance calendar.
Regulatory Updates
SAP delivers legal changes via SAP Notes; the Regulatory Change Manager shows their status.
SAP has indicated that it will cover Spain's B2B mandate within DRC, as it did for SII. Scope and release dates must be confirmed in SAP Notes and the Regulatory Change Manager once the order is published.
Choosing the Connection Route
Best for international groups, EDI-heavy or multi-format partners.
Best for mainly domestic B2B with a strong SAP team.
Best for large groups with a mixed customer base.
What Changes, by Role
Payment behaviour becomes visible to the authorities; compliance risk sits in finance processes.
Tax codes, document types and numbering must map to the Spanish profile; daily monitoring; SAP ↔ SPFE ↔ SII reconciliation.
Supplier invoices arrive as data, not PDFs; formal rejections; payment dates reported for every invoice.
Customer rejections visible in SAP; optional collection and non-payment reporting; factoring and confirming flag.
Correct tax IDs and addresses for every business partner. Clean-up before testing.
SAP Notes, BTP connectivity, certificates, user roles, test landscape, archiving.
Lessons Learned from SAP DRC Projects
Most issues come from user roles and connectivity — plan security and BTP set-up early. Stay on standard: custom middleware is complex and costly to maintain. Master data first: most rejections start with a wrong tax ID or tax code. Daily monitoring by tax/accounting, with a clear path to sales, finance and IT for fixes. Right skills: the team needs SAP BTP and Fiori security experience, not only FI. One event, three flows: design SII/VERI*FACTU, e-invoice and payment status together.
How 30 Advisory Can Help
A founder-led boutique specialised in SAP DRC & e-invoicing, S/4HANA Finance and CFO/CIO advisory. We take you from the mandate to a working, auditable SAP solution.
Readiness assessment and route decision
Applicable date, companies affected, current SAP and invoicing landscape. Route decision (platform, direct or hybrid) with cost and risk analysis.
Fit-gap and finance design
Fit-gap against the order and SAP DRC standard; finance design for tax codes, numbering, corrective invoices and payment statuses. One design for SII / VERI*FACTU, e-invoicing and payments.
eDocument Cockpit implementation
eDocument Cockpit implementation & configuration, SAP BTP connectivity, inbound and payment-status automation. Statutory reporting automation and reconciliation SAP ↔ SPFE.
End-to-end tests and cut-over
End-to-end tests in the AEAT test environment: rejections, duplicates, outages, payments. Cut-over, user training, procedures and evidence pack for auditors.
Ongoing monitoring and roadmap to ViDA
Ongoing compliance monitoring: SAP Notes, AEAT updates, KPIs and hypercare. Roadmap to ViDA (2030) and other country mandates.
Founder-led
Finance + SAP DRC depth
Multi-country: Italy, Turkey, Spain
Boutique agility
Crea y Crece, ViDA and your S/4HANA plans in one programme. Follow our ViDA Tracker at 30advisory.com.
Legal & Auditor Roles
The AEAT does not certify software: it publishes rules and a test environment. Each company must be able to prove compliance. Separation of duties: whoever builds the solution should not certify it.
Scope, exclusions, regional rules. Powers of attorney, contracts with platforms. Late-payment law, data protection.
Conformity audit and private certification (e.g. LCC-SPFE: 40 controls). Annual review and expert reports.
Design, build and run the SAP solution. Provide the evidence auditors need.
Key Dates
Order published; AEAT test environment
E-invoicing and payment reporting, turnover > €8M
All other companies; SME payment reporting
Payment reporting, individuals ≤ €8M
EU ViDA cross-border reporting
Next Steps
Diagnose & decide
Design & prototype with the AEAT environment
Build, test, interim audit
Certify & go live
Operate & monitor
Obliged in 2028? Your large customers go live in 2027 — be ready to receive invoices and report payments by then.
Mandate information summarised from the dossier "La Solución Pública de Factura Electrónica, explicada tras el seminario de la AEAT del 10 de septiembre de 2026" by Luis Vilanova, CISA — CEO & Lead Auditor, Legal & Digital Auditors, SL (www.leycreaycrece.com). Full credit to the author for the regulatory analysis and the LCC-SPFE framework. SAP content based on SAP DRC documentation and training material; the SAP impact and service sections are 30 Advisory's own.
The order is not yet published in the BOE and may change. Information only — not legal or tax advice.
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