Facturae vs UBL: Which E-Invoice Format Do You Need in Spain?

Spain's e-invoicing system spans two eras of format design: Facturae, a national XML format built for B2G invoicing over a decade ago, and UBL (Universal Business Language), the internationally standard format mandated for the public side of the newer B2B system. Which one applies to you depends on which of Spain's mandates you're dealing with.

Quick Comparison

	Facturae	UBL
Origin	Spain-specific national format	International standard (OASIS), widely used across the EU
Used for	B2G invoicing via FACe (since 2015)	Mandatory for Spain's public AEAT B2B platform
Also accepted for B2B	Yes, via accredited private platforms	Yes — the default for the public solution
EN 16931 alignment	Facturae has EN 16931-aligned profiles	UBL is one of EN 16931's two core syntax bindings
Cross-border use	Spain-specific, rarely used outside Spain	Widely used across the EU (Peppol BIS is UBL-based)

Facturae: Spain's Established B2G Format

Facturae has been the required format for invoicing Spanish public administrations since 15 January 2015, submitted through the FACe platform under Ley 25/2013. It remains fully in force and unaffected by the newer B2B developments.

For the upcoming B2B mandate under the Crea y Crece law, Facturae also remains an accepted format — but only via accredited private platforms, not the free public AEAT solution.

UBL: The Format for Spain's New B2B Public Platform

Royal Decree 238/2026 and its accompanying draft Ministerial Order confirm that UBL is the mandatory syntax for Spain's free public AEAT B2B e-invoicing platform. If you plan to use the government's free solution rather than a paid private platform, your software needs to generate UBL, not Facturae.

UBL is not new to EU e-invoicing — it's one of the two syntaxes explicitly permitted under EN 16931 (alongside UN/CEFACT CII) and forms the basis of Peppol BIS, the format used across Belgium, Poland, Italy's cross-border traffic, and several other EU Peppol-based mandates. Choosing UBL-capable software in Spain therefore has a side benefit: it's a format your accounting system may already produce if you invoice cross-border into other EU markets.

CII and EDIFACT: Also Accepted, Rarely the Default Choice

Spain's B2B system additionally accepts CII (UN/CEFACT Cross Industry Invoice) and EDIFACT via accredited private platforms. In practice, most Spanish SMEs and freelancers are unlikely to need either directly — these matter more for larger businesses with existing EDI infrastructure built around one of these syntaxes, or for cross-border trading partners who already exchange invoices in CII.

Which Format Do You Actually Need?

Invoicing Spanish public bodies (B2G) → Facturae via FACe. This hasn't changed and won't.
Planning to use the free public AEAT platform for B2B (once the mandate applies to you) → UBL is mandatory.
Using an accredited private platform for B2B → Facturae, UBL, CII, or EDIFACT, depending on what your chosen platform and software support.
Already trading with Peppol-mandated EU countries → your existing UBL capability likely transfers directly to Spain's public B2B platform.

What to Ask Your Software Vendor

Does your invoicing software generate UBL, not just Facturae? Many Spain-focused tools built for FACe compliance only produce Facturae and may need updating for the B2B mandate's public-platform option.
If you plan to use a private platform instead, which of the four syntaxes does that specific platform require or convert automatically?

See our Spain software comparison for vendors and their current format support, and the complete Spain regulations guide for the full mandate timeline.

Last updated: August 2026. Format requirements are based on Royal Decree 238/2026 and its draft implementing Ministerial Order; final technical detail may be refined before the order takes effect.