E-invoicing in Spain: Upcoming changes and how to prepare for them

Spain is one of the European Union countries actively working on implementing mandatory e-invoicing. Although e-invoicing has been mandatory for transactions with public entities over 5000 euros since 2015, similar requirements are planned for B2B transactions as well. In this article, we will outline what these changes mean for e-commerce sellers.

Timeline for implementing e-invoicing in Spain

In 2015, Spain introduced mandatory e-invoicing for transactions with public entities (B2G), significantly increasing transparency and efficiency in administrative processes. Currently, there are plans to extend mandatory e-invoicing to B2B transactions. While the exact implementation date is not yet known, it is expected to occur in the summer of 2025. According to the plans, the new regulations will come into force 12 months after their publication in the Official State Gazette (BOE). In the first year, the regulations will apply to the largest taxpayers (with annual turnover exceeding 8 million euros), and a year later, they will cover all other companies.

If you want to know the implementation dates for mandatory e-invoicing in other EU countries, please refer to our article: Mandatory e-invoicing for B2B and B2G in Europe: Implementation deadlines.

Who will be required to use e-invoicing?

The obligation to use e-invoicing will apply only to domestic B2B transactions, meaning international transactions where one party is not based in Spain will be excluded. Similarly, transactions documented with simplified invoices and those not requiring an invoice, such as B2C transactions, will be exempt. It’s also worth noting that in the initial phase of mandatory e-invoicing, companies will be required to issue electronic invoices in PDF format to ensure readability for businesses not yet obliged to accept e-invoices.

E-invoicing system

The Spanish e-invoicing system will be based on several key elements:

1. Private provider platforms: Companies using these solutions will need to make their e-invoice exchange points available for communication with other companies. If they fail to do so, the default entry point will be the public e-invoicing solution. Additionally, companies using private platforms must send a copy of each invoice to the public platform in Facturae syntax.
2. Public e-invoicing solution: This will be managed by the National Tax Administration (STAA) and will also serve as an invoice repository. The public solution will be available to all companies that choose to use it.

E-invoicing process

The e-invoicing process in Spain involves cooperation between e-invoicing solution providers in an interoperability model. They will be required to connect to any platform within a month of receiving such a request from their clients. E-invoice recipients will be obligated to inform issuers of the invoice status on an ongoing basis, including acceptance, rejection, and payment date. This information must be forwarded to the STAA within four calendar days. This will allow the STAA to obtain statistics on invoice payments, facilitating monitoring of compliance with payment terms under Law 3/2004.

Required e-invoice format

The e-invoice format for B2B relationships in Spain must comply with the EN 16931 standard. The following formats will be accepted:

• CII (CEFACT/ONU): XML messages for industry invoices
• UBL (ISO/IEC 19845:2015): Messages for invoices and credit notes
• EDIFACT (ISO 9735): International standard for trade messages
• Facturae: National XML standard, also used in B2G relationships

Archiving e-invoices

E-invoices must be stored for at least six years. They can be stored abroad, provided specific security and accessibility requirements are met. Companies must ensure that archived e-invoices are available upon request from control authorities and stored in a manner that guarantees their integrity and authenticity.

Integrity and authenticity of e-invoices

To ensure the integrity and authenticity of e-invoices, they must be signed with an advanced electronic signature. Additionally, each e-invoice must be marked with a unique QR code containing information on the issuer’s tax identification number, invoice number, issuance date, and invoice series. This allows for easy and quick verification of document authenticity.

Preparing for e-invoicing

For e-commerce sellers, preparing for mandatory e-invoicing is crucial. Here are some steps to smoothly implement the new regulations:

1. Invest in appropriate software: Invest in systems for issuing and receiving e-invoices that comply with the technical and legal requirements of the Spanish e-invoicing system.
2. Employee training: Employees responsible for invoicing and accounting should be adequately trained on the new regulations and e-invoicing systems.
3. Collaboration with providers and clients: Establish cooperation with e-invoicing solution providers and inform clients of the upcoming changes. This ensures smooth invoicing processes and avoids potential issues.
4. Monitor legislative changes: E-invoicing regulations may change, so it’s important to stay updated and adapt to new requirements.

Benefits of e-invoicing

Although the introduction of mandatory e-invoicing may initially seem challenging, the benefits are significant. Automation of invoicing processes, increased transparency, and better payment control can improve operational efficiency and reduce administrative costs. For e-commerce sellers, who often handle a large number of transactions, these benefits can be particularly important.

E-invoicing also facilitates easier financial data management and faster information on payment status, enabling sellers to better manage cash flow and avoid payment delays.

Summary

The introduction of mandatory e-invoicing in Spain is a step towards digitization and modernization of business processes. For e-commerce sellers, it means the need to adapt to new requirements but also an opportunity to improve operational efficiency and financial control. It is advisable to start preparations now to be ready for the upcoming changes and make the most of the opportunities e-invoicing offers. Keeping up with further information on mandatory e-invoicing and collaborating with providers and clients will ensure smooth implementation of the new regulations and avoid potential problems.