All About e-Invoicing in Spain

The Spanish government introduced a new law for creating and growing businesses and officially published it in September 2022. However, this law is not related to taxes but focused on strengthening industries and businesses in Spain. The government aimed to speed up the formation of companies, improve the regulations to develop economic activities and ease access to financing.

Among many measures approved under this new law, implementing mandatory electronic invoicing (e-invoicing) for businesses and professionals is crucial. Currently, e-invoicing is applicable only in the case of Business to Government (B2G) transactions.

In June 2023, the Spanish government published the e-invoicing for draft regulations. Even though it is in the public consultation stage, businesses and professionals must understand the Spanish laws and the scope of mandatory e-invoicing.

Accordingly, this article explains all about e-invoicing in Spain, including, what it is, its applicability, and draft regulations.

What is e-invoicing in Spain?

The business must share the invoice data with the government and get it validated for further use. The e-invoice issuer shall use a public or private platform to generate an e-invoice.

All businesses and professionals must follow e-invoicing when both are established in the Spanish territory. However, e-invoicing is not applicable if the invoice issuer or recipient is not a Spanish business or professional.

It is clarified that e-invoicing does not apply to simplified invoices issued in Business to Consumer (B2C) transactions. It is to be noted that businesses ]can issue a B2C e-invoice for a B2B transaction subject to certain amount limits.

Applicability of e-invoicing in Spain

The Spanish government mentioned the below timelines for the implementation of mandatory e-invoicing:

Draft regulations on Spain e-Invoicing

Spanish businesses and professionals shall note the below points from the draft e-invoicing regulations:

• e-Invoices must contain mandatory fields, and they can add additional fields.
• The recipient of the e-invoice shall report one of the mandatory statuses of invoices, such as accepted, rejected and paid. They can also add additional statutes as acceptances or partial payments.
• The e-invoices must be issued in XML, UBL, and EDIFACT format.
• Each e-invoice must be issued with an electronic signature. However, this requirement does not align with the European Commission’s VAT in the Digital Age (ViDA) proposal.
• The platforms must interconnect among themselves and be able to access e-invoices. 
• The e-invoicing platforms must be places that function as a repository of invoices.
• Businesses may use either public or private platforms to exchange invoice data.
• A copy of the invoice must always be sent to the public platform when using a private invoicing platform.
• Further, the Spanish administration might prefer the current ‘Fracture’ system for B2B e-invoicing as well.

What are the next steps in Spanish e-invoicing?

The government already announced the applicability of e-invoicing for Spanish businesses based on the turnover and approval of e-invoicing regulations. With only draft regulations published, businesses can expect the government implements mandatory e-invoicing at the end of 2024 and 2025, respectively. 

However, Spain might be planning to implement e-invoicing in line with the VAT in the Digital Age (ViDA) initiative by European Commission.