E-Invoicing in Spain

Mandatory Electronic Invoicing in Spain

Learn how to get your company ready to exchange documents in accordance with regulations in Spain with the support of Comarch

B2B E-Invoicing
Implementation Timeline

Since 2015, Spain has had mandatory e-invoicing for transactions with public entities on contracts valued higher than EUR 5,000.

The Spanish authorities plan to make B2B e-invoicing mandatory in the near future. Giving an exact date of its entry into force is somewhat difficult at this stage, but it seems unlikely that it will take place in July 2024 as planned. This is because the B2B regulations will not enter into force until 12 months after publication in the Official State Gazette, and this has not yet taken place. It is known, however, that 12 months after the publication of the final regulations, large taxpayers (turnover in excess of EUR 8 million) will be covered by them, and after another 12 months, they will become applicable to all other taxpayers.

Within the first 12 months from the entry into force of the Royal Decree, companies will be required to issue e-invoices with a PDF document ensuring their legibility for companies for which the obligation to receive e-invoices has not yet entered into force.

Who is obliged to use e-invoicing

Who is obliged to use e-invoicing in Spain?

The e-invoicing obligation will apply only to domestic B2B transactions, which means that cross-border B2B transactions when one party is not established or has a permanent establishment in Spain will be exempt. The exemption will also apply to transactions documented with simplified invoices and those that do not have to be documented with an invoice (such as B2C transactions).

E-invoicing process description

E-invoicing system description

The elements of the Spanish e-invoicing system will be:

Platforms of private providers of electronic invoice exchange systems. Companies using this solution will have to make their e-invoicing point public in all communications with other companies. If they don't do it, the public e-Inv solution will be considered their entry point by default. In addition, if this solution is used, taxpayers will be required to upload to the public platform a faithful copy of each invoice in the Facturae syntax.
Publicly available solution for electronic invoicing, which will also be an invoice repository, be managed by the State Tax Administration Agency (STAA).

E-invoicing process description

Spain assumes the cooperation of suppliers of e-invoicing solutions in the interoperability model. They will be required to connect to any other platform, no more than one calendar month from receiving a request to do so from their customers.

Recipients of e-invoices will be obliged to keep issuers informed about the status of invoices on an ongoing basis. In particular, the statuses will refer to acceptance or rejection of the invoice and the date of payment. This information must be submitted within four calendar days to the STAA, which will provide the necessary mechanism to handle it. These provisions do not apply to the invoice statuses and the manner of their communication to the public platform.

On this basis, and on the basis of data sent to the publicly available portal, STAA will obtain statistical information on invoice payments that will facilitate monitoring of compliance with the provisions on payment deadlines, as described in ACT 3/2004.

What is the required format of an e-invoice

What is the required format of an e-invoice?

For B2G relations, the Facturae format is used. This is the XML-based national standard (used in association with an eSignature following the XAdES standard).

The format of B2B e-invoices in Spain must comply with the EN 16931 standard. The following will be accepted:

CII Industry-wide CEFACT/ONU Invoice XML message as specified in XML Schemas 16B (SCRD- CII)
UBL Invoice and Credit note messages in accordance with ISO/IEC 19845:2015
EDIFACT invoice messages compliant with ISO 9735
Facturae messages (version for invoicing between businesses and professionals), valid at all times

Archiving requirements for e‑Invoicing in Spain

Required storage period is 6 years.

How integrity and authenticity may be ensured?

E-invoices have to be signed by the issuer with an advanced electronic signature. In addition, all e-invoices will have to be identified with a unique QR code, which will include information about the issuer's tax identification number, invoice number, invoice date and series.