If you run an SME or an online store and invoice other businesses, Order HAC/1028/2026 (Spain’s Official State Gazette, 5 October 2026) has already started the countdown for mandatory B2B electronic invoicing. It regulates the AEAT public solution, the faithful UBL copy and payment-status rules, and starts the calendar by turnover. Also on 5 October, Spain’s Ministry of Finance announced plans to delay Verifactu until October 2028, a change not yet published in the BOE; B2B e-invoicing keeps its timeline. Below is what the official text says, how this differs from Verifactu, and what to check in your ERP, store or invoicing SaaS. This is not legal or tax advice: confirm scope and deadlines with your advisor.
What the BOE published on 5 October 2026
Order HAC/1028/2026 of 2 October sets the technical rules for the public e-invoicing solution foreseen in Royal Decree 238/2026. Under its sole final provision, it enters into force the day after its BOE publication: 6 October 2026.
From that date, the deadlines in final provision 8 of Law 18/2022 and in transitional provisions 1 to 3 plus final provision 4 of RD 238/2026 start to run. The countdown for electronic invoices between businesses and professionals is open.
What the Order (and RD 238/2026) requires
Spain’s system mixes private platforms and a public solution run by the Tax Agency. Three points from the official text matter to most SMEs and online stores:
1. Faithful UBL copy to the public solution. If you issue invoices through a private platform, solution or system (not the public one), you must send AEAT, at the same time as issuance, a faithful electronic copy of each invoice in UBL syntax. That is article 4 of the Order and article 6 of RD 238/2026. 2. Payment and rejection status. The recipient must report to the public solution any rejection, the date of full effective payment and the payment due date (article 7 of the Order; the framework sits in article 2 bis of Law 56/2007 and article 12 of RD 238/2026). The issuer may report collection or non-payment. 3. Public platform readiness. Additional provision 2 of the Order requires the public solution to be available on the AEAT electronic headquarters at least two months before the first effective application.
The public solution uses the EN 16931 semantic model under UBL syntax. There will also be a free web form on the AEAT site to issue and consult invoices, aimed especially at SMEs and professionals who prefer not to use a private platform.
Timeline by size: what the BOE actually says
Law 18/2022 (final provision 8) states that article 12 on e-invoicing between businesses and professionals takes effect one year after the regulatory development is approved for those with annual turnover above eight million euros, and two years later for everyone else.
RD 238/2026 spells out that development. Its final provision 4 (also summarised by the AEAT) says effective application is counted from the entry into force of the ministerial order on the public solution:
- Twelve months later, for businesses and professionals whose volume of operations, calculated under article 121 of the VAT Act, exceeded €8 million in the immediately preceding calendar year.
- Twenty-four months later, for remaining businesses and professionals.
Taking 6 October 2026 as the Order’s entry into force, the arithmetic points to 6 October 2027 for the above-€8m threshold and 6 October 2028 for the rest. The BOE does not print those two calendar dates; they are the sum of the relative periods. If your turnover is near the threshold, or if special rules apply (for example private-platform duties at twelve months under paragraph 2 of the same final provision 4), check with your advisor.
B2B e-invoicing versus Verifactu
Verifactu (rules for computerised invoicing systems, RD 1007/2023) requires billing software to create a billing record with integrity controls, and the invoice to carry a QR code. According to the AEAT itself, those records do not contain the full invoice information and are in no case electronic invoices. You may still issue on paper or as a structured e-invoice; the record is separate.
Mandatory B2B e-invoicing (Law 18/2022, RD 238/2026, Order HAC/1028/2026) is the structured exchange of the invoice between businesses and professionals, with a mandatory repository on the public solution (or a faithful copy if you use a private platform) and payment-status reporting. Its main goal is commercial late payment and payment-term traceability.
They can coexist: one transaction may produce a B2B e-invoice and also the Verifactu record your software must keep. Meeting Verifactu does not waive B2B e-invoicing when your calendar date arrives, or the other way around.
Verifactu delay announced; B2B e-invoicing unchanged
On 5 October 2026, Spain’s Ministry of Finance published an information note announcing that it will push the Verifactu obligations under RD 1007/2023 that do not yet apply back to October 2028. The aim is to line them up with mandatory e-invoicing for businesses and professionals with annual turnover up to €8 million.
For now this is an announcement, and the change is not yet published in the BOE. Until it is, the deadlines in final provision 4 of RD 1007/2023 still apply: corporate income tax payers must have their invoicing software adapted before 1 January 2027, and other obligated taxpayers before 1 July 2027.
The note does not touch B2B e-invoicing, whose deadlines still come from Law 18/2022 and RD 238/2026: 12 months from the Order’s entry into force for turnover above €8 million, and 24 months for everyone else.
What to check in your software (and how we help)
For an SME or a Shopify or WooCommerce shop, check whether your current stack can issue, receive and report statuses when your deadline hits:
- Where the invoice is born. ERP, POS, invoicing SaaS or the store module? Whoever issues will need to produce UBL (or connect to someone who does) and, if not using the public solution, send the faithful copy.
- B2B customers. The duty covers transactions between businesses and professionals with a Spanish establishment (article 3 of RD 238/2026). A consumer ticket is a different case; a B2B order with a tax ID is in scope.
- Receiving and status. Issuing alone is not enough: you must also receive e-invoices and report payment or rejection. Accounting, treasury and software need to talk.
- Shopify, WooCommerce and marketplaces. Many stores invoice through apps or a linked ERP. Check whether that connector covers UBL, the copy to the public solution and status reports, or whether you will need another integration.
- Verifactu in parallel. If your software already adapts to Verifactu (QR, record), ask the vendor how that sits next to B2B e-invoicing: they are different layers. If the delay is published, businesses with turnover up to €8 million will face both at the same time, so it makes sense to prepare the software for both in one project.
LetBrand is not an e-invoicing provider and does not give tax advice; we adapt and connect your website, online store or integrations with the ERP and SaaS tools you already use. For a first technical look, the next step is the €150 one-off web review. If the ERP, the shop or the SaaS needs a custom adaptation, we then send a proposal. To talk it through, contact us.