Payment statuses in e-invoicing: the tax authorities will see when you pay

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Mandatory B2B e-invoicing doesn’t just change how invoices are issued: it also requires the party receiving them to report what happens to them. With Order HAC/1028/2026, published in the BOE (Spain’s Official State Gazette) on 5 October and in force since 6 October, the Spanish Tax Agency’s service for reporting invoice statuses and payments is now regulated. The recipient will have to notify whether they reject an invoice, what its due date is and when it has been paid in full. It will first apply to companies with an annual transaction volume above 8 million euros (from 6 October 2027) and then to everyone else.

Which statuses must be reported

Royal Decree 238/2026, which implements Law 18/2022 (Crea y Crece), distinguishes between mandatory and voluntary statuses, and Order HAC/1028/2026 specifies how they are sent to the AEAT’s public solution:

  • Mandatory for the recipient: rejection of the invoice (if they reject it), the due date of the payment term and the date of full, effective payment.
  • Voluntary for the recipient: partial acceptance or rejection, partial payment, assignment of the invoice to a third party, or receipt of the goods or services.
  • Voluntary for the issuer: reporting that payment has been received or is outstanding, and flagging differences with the dates reported by the customer.

In the public solution, an invoice is deemed accepted if it is neither rejected nor followed by a corrective invoice. In other words, not responding is the same as accepting.

The deadline: four days from payment

Article 12 of the Royal Decree establishes that full payment and its effective date must be reported within a maximum of four calendar days from that date, not counting Saturdays, Sundays or national public holidays. Under Article 10, the same deadline applies to the other statuses from the moment they occur.

The order provides for two ways of submitting the information: through web services (first identifying the invoice by its unique code) or through an individual form on the AEAT’s electronic office. Erroneous submissions can be cancelled, leaving an audit trail.

There is one useful exception: if the invoice itself already shows a payment date on or before the issue date (for example, a sale paid in cash), the obligation to report the payment is considered fulfilled.

Why we call it late-payment monitoring

The stated aim of the system is to reduce late payment in commercial transactions. The payment term is calculated using the rules of Law 3/2004 on combating late payment, and the Royal Decree provides for the AEAT to send the State Observatory on Private Late Payment, every year, the information needed to draw up the list of companies that fail to meet payment deadlines. That is why we say the tax authorities will see when you pay: the due date and the actual payment date will be recorded invoice by invoice.

Timeline

The deadlines run from the entry into force of the order, 6 October 2026:

  • 6 October 2027: companies and self-employed professionals with a transaction volume above 8 million euros.
  • 6 October 2028: all other companies and professionals must issue and receive electronic invoices; legal entities must also report statuses and payments.
  • 6 October 2029: individuals (self-employed workers) and entities under the income attribution regime become obliged to report statuses and payments; until then it is voluntary for them.

What about Gipuzkoa and the rest of the Basque Country?

The Royal Decree devotes its third additional provision to the foral territories: for companies subject to foral regulations, the public solution will be governed by the provisions of the Economic Agreement (Concierto Económico), and agreements will be established between the foral tax authorities and the AEAT. To date, those agreements have not been published, so we do not yet know how or to whom companies in Gipuzkoa will report their payment statuses. Our recommendation is not to wait for that detail before organising your internal processes: the information to be provided (due dates and actual payment dates) will be the same.

What this means for your company

This is the change the accounting department will notice most. With a margin of four working days, the payment date has to be recorded in the ERP almost the moment the money leaves the account. This is what we see in the companies we work with:

  • Reliable due dates on every supplier invoice. Payment terms must be correctly configured for each supplier; an incorrectly calculated due date will be reported just as incorrectly.
  • Daily bank reconciliation. In Odoo 16, statement import and reconciliation models make it possible to match payments with almost no manual intervention, but it takes time to fine-tune them properly.
  • Batch payments and grouped payments. A payment that settles several invoices must be reflected on each of them; it is worth reviewing how SEPA batch payments and partial payments are currently being recorded.
  • A clear rejection process. Since silence is equivalent to acceptance, you need to decide who reviews received invoices and within what timeframe incorrect ones are rejected.

The reporting itself should be automatic. Once the AEAT publishes the technical specifications of the web service, status submission could be triggered from the ERP itself or from n8n automation workflows that read the reconciliation and report payments without manual work. With the support of Future AI, part of the Binovo Group, it is also possible to consider artificial intelligence for Odoo agents that help review received invoices and detect those that should be rejected. Some technical pieces are yet to be published, but organising your data and processes can start right now.

If you would like to review how your due dates, reconciliation and invoice reception are set up today in your Odoo ERP, get in touch and we will go through it with you.

Binovo is developing two solutions for this obligation. If you use Odoo, an e-invoicing module that will be public on our GitHub: we explain it in E-invoicing in Odoo. If you use other software, the B2B e-invoicing API (in Spanish), built on the same API Verifactu technology. On that page we also compare Verifactu and B2B e-invoicing, because they are two different obligations.

Sources

Transparency: this article was prepared with the help of artificial intelligence based on the sources cited and was reviewed and validated by the Binovo team before publication.

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