SPFE: e‑invoicing without changing tools

Spain’s Public e‑Invoicing Solution (SPFE) is the public platform for mandatory e‑invoicing between businesses and professionals. The order entered into force on 06/10/2026, activating phased obligations on 06/10/2027, 06/10/2028 and 06/10/2029, according to the Spanish Tax Agency (AEAT) AEAT. You can integrate SPFE with your current software, such as Holded, to comply without switching tools.

Key takeaways

• SPFE is regulated by Order HAC/1028/2026 and took effect on 06/10/2026, starting the compliance timeline, according to the Spanish Tax Agency (AEAT) AEAT.
• At 12 months (06/10/2027), businesses with turnover > €8m must issue, send and receive e‑invoices and report invoice/payment statuses AEAT.
• At 24 months (06/10/2028), the rest must e‑invoice; legal entities ≤ €8m must also report invoice/payment statuses AEAT.
• At 36 months (06/10/2029), individuals and income‑attribution entities must report invoice/payment statuses AEAT.
• You can comply by integrating SPFE with your current tool; in Holded, approach it through configuration, integration, testing and training.

SPFE explained: what it is and what changes

Spain’s Public e‑Invoicing Solution (SPFE) is the public platform underpinning mandatory e‑invoicing between entrepreneurs and professionals. The framework is set by Order HAC/1028/2026, published in the Official State Gazette (BOE) and developed under Royal Decree 238/2026 and Law 18/2022, as noted by the Spanish Tax Agency (AEAT) AEAT. The order entered into force the day after publication, on 06/10/2026, which starts the calculation of the official rollout deadlines AEAT.

In practice, SPFE sets a common channel to issue, send and receive e‑invoices across business‑to‑business transactions and introduces the obligation to report specific invoice and payment statuses on a phased schedule. These milestones depend on your turnover and legal form and will affect your sales, purchasing and treasury workflows. From the effective date (06/10/2026), obligations are deferred by 12, 24 and 36 months for different groups, exactly as described by AEAT AEAT.

If you already work with invoicing software, you do not need to abandon it. You can integrate SPFE so that your team continues creating, approving and booking invoices in your current setup while routing outbound and inbound e‑invoices through the public system and updating the required status/payment information at each stage, according to the official schedule AEAT. In Spain you will also see the keyword “SPFE factura electrónica” in official and industry conversations.

Official timeline: who is affected and from when

The application of obligations is phased from 06/10/2026 in three steps, according to the official calendar AEAT:

• After 12 months (06/10/2027): entrepreneurs and professionals with turnover > €8 million. Obligation to issue, send and receive e‑invoices and to report invoice and payment statuses AEAT.
• After 24 months (06/10/2028): the rest of entrepreneurs and professionals. Obligation to issue, send and receive e‑invoices. In addition, for legal persons with turnover ≤ €8 million, obligation to report invoice and payment statuses AEAT.
• After 36 months (06/10/2029): individuals and entities under the income‑attribution regime must report invoice and payment statuses AEAT.

These dates are counted from the order’s entry into force (06/10/2026), and they determine when each group must be ready to operate fully in e‑invoicing and, where applicable, status/payment reporting. Plan backwards from your milestone: allow time to cleanse data, define processes, integrate, test and train so you reach production stability well ahead of your legal date. If you are close to the 12‑month group, aim for a live pilot months before 06/10/2027; smaller entities should target production readiness months before 06/10/2028; individuals and income‑attribution entities should have their reporting process rehearsed before 06/10/2029, all as per AEAT’s milestone description AEAT.

What you must comply with: e‑invoicing and status/payment reporting

The regulation introduces two operational obligations, as described by the Spanish Tax Agency (AEAT) AEAT:

• Mandatory e‑invoicing: issue, send and receive electronic invoices between entrepreneurs and professionals, following the phased entry dates relevant to your group.
• Information on invoice and payment statuses: communicate specified statuses of the invoice and payment information, depending on your size and legal nature, on the dates indicated.

To comply, review the full invoice lifecycle:

• Sales: create the e‑invoice, route it through the SPFE channel and track its status from submission to acceptance/rejection.
• Purchasing: receive inbound e‑invoices through the same channel, record them, validate them and manage approvals.
• Treasury: reconcile payments and update the required status/payment information when applicable.

The practical cornerstone is end‑to‑end traceability: who issued/received each invoice, which channel carried it, what its current status is and what payments have been made. Map exceptions (rejections, amendments, credit notes) and ensure the required status updates are posted in line with the relevant milestone for your entity type and turnover bracket, as outlined by AEAT AEAT.

Preparing your business for SPFE: an operational checklist

Before integrating SPFE, put your house in order to reduce friction during go‑live. A practical checklist:

• Master data: cleanse tax IDs, legal names, addresses and contact emails for customers and suppliers. Ensure each counterparty is uniquely identified.
• Numbering: define sequences and avoid duplicates. Clarify how you handle corrections and credit notes.
• Products/services: standardise descriptions, units and tax categories. Minimise free‑text fields.
• Approval circuits: document who approves sales and purchases and in what conditions.
• Treasury: adopt consistent reconciliation practices so you can update status/payment information smoothly.
• Archiving and audit: decide how you will retain evidence of submission/reception and status changes.

Governance and roles

Create a cross‑functional team (operations, admin, IT). Assign clear owners for:

• Integration design and testing.
• Incident management and internal support.
• Training and documentation.

Testing and pilot

If your software offers a test environment, use it. Define end‑to‑end test cases: issuance, acceptance/rejection, amendment, reception and payment reconciliation. Run a controlled pilot with a limited set of customers and suppliers to validate day‑to‑day operations. This groundwork will let you start posting the required e‑invoices and status/payment updates on your legal date, aligned with AEAT’s phased obligations AEAT.

Connecting SPFE without switching tools

You can integrate SPFE while keeping your current invoicing system, provided it supports the necessary connection and data mappings. A general approach:

1. Confirm scope: verify your solution can issue, send and receive e‑invoices and, when applicable, report invoice/payment statuses in line with the phased dates set out by AEAT AEAT.

2. Design the flows: define how each invoice leaves your system, how status updates are captured and how payment information will be reflected. Assign responsibilities across sales, purchasing and finance.

3. Implement the integration: set up connectivity and field mappings between your tool and SPFE. Replace manual steps with automated routines wherever feasible.

4. Test and monitor: execute structured test suites, run a pilot and track KPIs (rejection rate, acceptance lead times, payment traceability) to stabilise operations.

If you use Holded, you can follow this same pattern within your account, keeping your existing sales and purchasing flows and adding the e‑invoicing channel to and from SPFE. For specialist help, consider an experienced partner for the Holded Implementation Service, targeted Process Automation with Holded and Personalized training at Holded.

Working in Holded: set‑up, testing and ongoing support

Without going into buttons, a pragmatic path in Holded typically includes:

• Configuring e‑invoice issuance and reception so series, taxes and counterparties align with your master data.
• Establishing the SPFE channel for outbound/inbound flow and for recording status/payment information as it becomes obligatory for your group and dates, per AEAT’s schedule AEAT.
• Creating templates and validations to minimise rejections.
• Automating the capture of statuses and, where required, payment information updates.
• Building operational views to track daily throughput and month‑end closures.

Controlled testing

• Emission scenarios with acceptance and with rejection.
• Reception of supplier e‑invoices and validation flow.
• Status updates and reflection of payments end‑to‑end.

Sustained operations

Define an incident process and a cadence for periodic updates. For continuity, lean on Holded Support and Maintenance and the expertise of a Holded Solution Partner Gold via the Agency Holded Solution Partner B2B page. If you are leveraging grants, review the Digital Kit for Process Management - Holded. Keep your operating model aligned with the phased SPFE obligations and dates from AEAT’s notice AEAT.

Roadmap by size: prioritise to meet your legal milestone

Align your plan to the official timeline counted from 06/10/2026 AEAT:

• €8 million turnover: be live before 06/10/2027 with e‑invoicing and status/payment reporting from that date AEAT.

• ≤ €8 million (legal entities): be live before 06/10/2028 with e‑invoicing and, for these legal entities, status/payment reporting from that date AEAT.
• Individuals and income‑attribution entities: prepare status/payment reporting for 06/10/2029 AEAT.

A four‑phase delivery pattern works well:

1. Discovery (4–6 weeks): assess data, flows and gaps.
2. Integration (6–10 weeks): connect to SPFE, map fields, run initial tests.
3. Pilot (4–6 weeks): operate with real users; control rejections/incidents.
4. Rollout and stabilisation (4–8 weeks): training, support and metrics.

Adapt durations to your complexity. Document responsibilities and escalation paths. At ARTIC we see that organisations which start early, establish clear ownership and iterate through a pilot reach their SPFE milestone with fewer incidents and better user adoption, in line with the phased obligations communicated by AEAT AEAT.

Frequently asked questions

What is SPFE and what is it for?

Spain’s Public e‑Invoicing Solution (SPFE) is the public platform supporting mandatory e‑invoicing between entrepreneurs and professionals. It is regulated by Order HAC/1028/2026 and, from its entry into force on 06/10/2026, it activates phased obligations, according to the Spanish Tax Agency (AEAT) AEAT.

When does SPFE affect me if my business turnover is over €8 million?

Twelve months from 06/10/2026, i.e., on 06/10/2027. From that date, you must issue, send and receive e‑invoices and report invoice/payment statuses, as indicated by AEAT AEAT.

What if I am a small or medium business or freelancer below €8 million?

After 24 months (06/10/2028), all other entrepreneurs and professionals must e‑invoice. In addition, legal persons in this bracket must report invoice/payment statuses from that date, per AEAT’s notice AEAT.

Do individuals have to report invoice and payment statuses?

Yes. After 36 months (06/10/2029), individuals and income‑attribution entities must report invoice/payment statuses, according to the Spanish Tax Agency (AEAT) AEAT.

Do I need to change software to comply with SPFE?

Not necessarily. You can integrate SPFE with your current invoicing software so you can keep your usual processes while meeting the new obligations on the relevant dates set by AEAT AEAT.

Can I start preparing before my legal deadline?

Yes, and it is advisable. Clean up master data, document processes, design the integration, and run tests and a pilot so you reach your AEAT‑defined milestone with a stable setup AEAT.

Want us to set this up in your Holded?

ARTIC is a Holded Solution Partner Gold. We help you implement Holded from scratch, automate invoices, collections and reminders, train your team and review and maintain your account every month. Tell us about your case and we will get it ready.

Sources

• : Solución Pública de Facturación Electrónica (SPFE)

Informative article, up to date on the publication date with the official sources linked. Regulations change: check your specific case with your tax adviser.