Mandatory e-invoicing in Spain: the 2027-2028 timeline for schools and academies

Mandatory e-invoicing between businesses in Spain had been announced for years without a date. Since 6 October 2026 it has a timeline. Order HAC/1028/2026, published in the BOE (Spain's official gazette) on 5 October, regulates the Tax Agency's public e-invoicing solution and, by entering into force the next day, starts the deadlines set out in Royal Decree 238/2026.

For a school, a nursery or an academy, the practical question has two parts: which invoices it issues to companies, and which invoices it receives from its suppliers. This article goes through the dates, who they affect and what is worth preparing.

The dates

The deadlines are counted from 6 October 2026:

• 6 October 2027: businesses and professionals with annual turnover above 8 million euros must issue, send and receive e-invoices, and report the status of invoices and their payment.
• 6 October 2028: all other businesses and professionals must issue, send and receive e-invoices. Legal entities with turnover of 8 million or less must also report status and payment.
• 6 October 2029: the self-employed and entities taxed under the income attribution regime, such as civil partnerships, start reporting the status and payment of their invoices.

The vast majority of schools invoice less than 8 million euros a year, so their date is October 2028. A large education group may exceed that threshold and have the 2027 date.

Which invoices are included and which are not

The obligation covers invoices between businesses and professionals. In a school, that means:

• Families are outside it. Receipts for fees, canteen or after-school activities issued to families are not invoices between businesses. They remain subject to Verifactu, which is a separate obligation with its own timeline, as we explain in the Verifactu postponement.
• Invoices you issue to companies are included. For example, an academy training a company's employees, including the subsidised training we cover in FUNDAE subsidies for academies, a school renting out its facilities, or a school providing services to another entity in its group.
• Invoices you receive from suppliers are included. Canteen catering, transport, maintenance, materials, cleaning or software. When their deadline arrives, your suppliers will send you e-invoices, and any supplier with turnover above 8 million will do so from October 2027.

That last point is often overlooked: even if a school never invoices a company, it does receive invoices from companies.

What changes compared with a PDF

A PDF invoice sent by email is not an e-invoice under this rule. The invoice must be generated in a structured format that software can read without human input, and travel through one of these channels:

• The Tax Agency's public solution: free, for issuing, receiving and consulting invoices. The public solution works with the UBL syntax and the European standard EN 16931.
• A private e-invoicing platform, which must be interoperable with the rest.

The rule also adds a new obligation: reporting the status of each invoice, whether it is accepted or rejected, and the date it is paid. The stated aim is to reduce late payment between businesses, and in practice it means that receiving and paying invoices must be recorded.

What to prepare

Most schools have until October 2028, but some of the work is better done calmly:

1. List what you invoice to companies: which items, how many clients and from which programme.
2. List what you receive: regular suppliers, number of invoices a month and who records them today.
3. Check your threshold: if the school, or the group, invoices more than 8 million euros, your date is October 2027.
4. Choose a channel: the free public solution or a private platform. Talk to your accountant, because the accounts are fed by these invoices. We cover it in the integration between the school and its accountant.
5. Ask your large suppliers how and when they will start sending you e-invoices.
6. Check who marks invoices as paid: the new obligation to report payment requires that information to exist and be up to date.

How it relates to Verifactu

They are two separate obligations that overlap. Verifactu governs the software used to issue invoices, all of them, including those to families. E-invoicing governs the format and channel of invoices between businesses. An invoice to a company issued with software will have to meet both.

That is why, on 5 October, the Finance Ministry announced its intention to move Verifactu to October 2028 as well: so that most businesses and professionals adapt to both at once. At the time of writing, that postponement has not yet been published in the BOE.

Conclusion

With Order HAC/1028/2026, e-invoicing between businesses now has dates: October 2027 for those with turnover above 8 million euros and October 2028 for everyone else. In a school, the impact is less about families, who are outside it, and more about invoices to companies and, above all, the invoices it receives from suppliers. Two years sounds like a lot, but listing invoices, choosing a channel and coordinating with your accountant takes time.

If you want invoicing to families in order, with Verifactu and SEPA direct debits on a single platform, see Edena's invoicing or book a demo.