Spain's B2B e-invoicing mandate finally has a start date. Order HAC/1028/2026 appeared in the Official State Gazette on 5 October 2026 and took effect the next day, and every deadline counts from 6 October 2026. A Spanish entity with a volume of operations above 8 million euros last year must issue and receive structured e-invoices from 6 October 2027. Everyone else follows on 6 October 2028. OpenText's update on the order puts it plainly: if you were waiting for a firm date, you now have one.
Most Spain plans start with sending. For an SAP AP team on OpenText VIM, the more interesting part is what Spain asks the buyer to send back.
The buyer reports, too. Spain built the mandate to fight late payment, so exchange is only half of it. The buyer must tell the tax agency (AEAT) when it rejects an invoice, the payment due date, and the date the invoice is paid in full. An invoice that isn't rejected is presumed accepted. OpenText's summary is blunt about whose job that is: accounts payable and treasury, not just whoever issues invoices.
Read that against a VIM process and three things change.
A rejection becomes a reported event. Inside VIM, rejecting an invoice back to the supplier is a workflow step with a reason. For Spanish invoices it becomes something the tax agency hears about. VIM CE 24.2 made rejection reasons mandatory in its Fiori apps, which helps, but those reasons were set up for your own process, not for a government status feed. Check what a Spanish rejection has to carry under the order's technical rules, then map your VIM reasons to it.
Parked is not rejected. An invoice sitting in a VIM exception queue, waiting on a buyer or a goods receipt, hasn't been rejected. Under the presumption rule, silence counts as acceptance. Decide how long a Spanish invoice may wait before AP either rejects it on purpose or accepts that it's accepted.
The payment date lives in SAP, not VIM. VIM gets the invoice posted. The date it's paid in full comes from the payment run and the bank statement. Whoever owns that feed, usually treasury, owns this line of the report.
What arrives at the door. Spain chose a mixed model. Invoices can travel through the AEAT's free public solution, through a private platform, or both. On the private route, every invoice must also go to the AEAT at the same moment as a faithful copy (copia fiel) in UBL. Private platforms may exchange UBL, UN/CEFACT CII, EDIFACT or Facturae, but the copy to the tax agency is always UBL on the EN 16931 model. Peppol can carry invoices between platforms, but it isn't the national network, and a Peppol connection alone doesn't make you compliant.
For one year, from 6 October 2027 to 5 October 2028, large companies must also send a readable PDF with each structured invoice unless the customer agrees to the structured invoice alone. If your capture design reads PDFs today, that year is your overlap. Decide which copy VIM treats as the invoice. We'd pick the structured one.
Receive before you issue. The threshold is assessed per Spanish entity, not on group revenue. Your own issuing date may be 2028, but your large Spanish suppliers start sending on 6 October 2027. On the VIM side, OpenText's SAP release blog lists out-of-the-box Spain mappings from VIM CE 24.2. That release predates this order, so confirm with OpenText which Spanish formats the mapping covers and what the current release adds. We covered inbound e-invoices as a channel and the ViDA dates earlier. Spain is the first mandate on that calendar where the AP status itself is reportable.
OpenText says its Trading Grid e-Invoicing service will connect to the AEAT solution, send the faithful copy and support status and payment reporting. Whatever carries the report, the values come from your SAP and VIM process. Name who owns each one: AP for rejections and their reasons, treasury for payment dates, the VIM process owner for the mapping between them.
Eleven months is enough time if the reporting design starts now.
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