Spain's B2B e-invoicing rules, in Royal Decree 238/2026, require invoices that follow the EN 16931 data model in CII, UBL, EDIFACT or Facturae. The tax agency's public solution uses a Spanish UBL specification and receives a UBL copy of every invoice.
The in-scope domestic B2B rules apply from 6 October 2027 for businesses above 8 million euros and from 6 October 2028 for the rest. Simplified invoices under article 4 of the invoicing regulation are excluded. Klarbon support is planned, not available yet.
What is in the Spanish UBL specification?
| Property | Value |
|---|---|
| Model | EN 16931, with Spanish terms BT-ES and BG-ES |
| Syntax | UBL, latest approved version |
| Business process, BT-23 | urn:aeat:names:specification:ubl:schema:profile:B2B |
| Specification identifier, BT-24 | urn:cen.eu:en16931:2026#conformant#urn:aeat.es:spfe:1.0.0:extended |
| Unique invoice code | issuer tax number, series, number and issue date |
| Invoicing system reference | VERIFACTU or TICKETBAI, with the URL of the QR code |
| Status messages | UBL Application Response, for acceptance, rejection and payment |
| Run by | the Spanish tax agency (AEAT) |
Order HAC/1028/2026 sets the content of the public solution's invoices, copies and status messages, with technical specifications on the AEAT electronic office (Order HAC/1028/2026). Royal Decree 238/2026 sets the formats, the duties of platforms and recipients, and the start dates (Royal Decree 238/2026).
When do the rules apply?
| Who | From |
|---|---|
| Private exchange platforms, for copies and interconnection | twelve months after the order, October 2027 |
| Businesses with turnover above 8 million euros | twelve months after the order, October 2027 |
| All other businesses and professionals | twenty-four months after the order, October 2028 |
For the first twelve months, businesses above 8 million euros add a readable PDF unless the recipient voluntarily and expressly accepts the original electronic format. The PDF copy is not sent to the public solution.
B2B rules or public sector invoicing?
Invoices to Spanish public bodies follow their own rules, in Facturae through the FACe entry points (Facturae). The B2B rules admit Facturae as one of the four syntaxes, but the B2B timetable and the public sector duty are separate.
What does Klarbon do with Spanish e-invoices?
Checking it is planned, not available yet. Klarbon opens supported UBL 2.1 and CII D16B EN 16931 invoices; see the invoice viewer. Klarbon does not send invoices or copies to the public solution.
Related
Frequently asked questions
When does B2B e-invoicing become mandatory in Spain?
Royal Decree 238/2026 applies twelve months after Order HAC/1028/2026 took effect for businesses whose turnover exceeded 8 million euros in the previous year, and twenty-four months after for everyone else. The order was published on 5 October 2026 and took effect the next day.
Which formats are allowed?
A structured message following the EN 16931 data model in CII, UBL, the EDIFACT invoice message or Facturae. Private exchange platforms must be able to transform between all of them.
What is the Spanish UBL specification?
The UBL profile of the public e-invoicing solution run by the tax agency (AEAT). Invoices carry BT-23 urn:aeat:names:specification:ubl:schema:profile:B2B and BT-24 urn:cen.eu:en16931:2026#conformant#urn:aeat.es:spfe:1.0.0:extended.
What if I use a private platform?
The platform must send a faithful copy of each invoice in UBL to the public solution as it is issued. The buyer reports acceptance or rejection and full payment, and payment must always be reported to the public solution.