Guide to e-invoicing requirements in Spain

While timelines have shifted and technical details are still being finalised, the direction is clear: digitisation is the future of invoicing in Spain as well. This guide breaks down what software vendors and businesses need to know about the current and upcoming e-invoicing landscape in Spain, ensuring you stay ahead of the curve.

Public sector e-invoicing: Mandatory nationwide
Private sector e-invoicing: upcoming mandates
E-invoicing standards and networks
Tax and compliance considerations
Conclusion

Public sector e-invoicing: Mandatory nationwide

Spain was an early adopter of e-invoicing in the public sector. Since 2015, all suppliers delivering goods or services to public administrations have been required to issue electronic invoices for amounts exceeding €5,000. Some administrations set lower thresholds.

The central hub for this e-invoicing is FACe (Punto General de Entrada de Facturas Electrónicas). This platform acts as the single entry point for e-invoices addressed to the central government. Suppliers must submit invoices in the Facturae format (an XML-based national standard) signed with an electronic signature (XAdES).

However, Spain’s decentralised administrative structure adds a layer of complexity. While FACe covers the central government and many regions, some autonomous communities, most notably the Basque Country, have their own platforms and specific requirements.

For software vendors, this means a "one-size-fits-all" approach rarely works. Your solution needs to be flexible enough to route invoices to FACe while accommodating regional variations where necessary.

Private sector e-invoicing: upcoming mandates

Following the success of B2G invoicing, Spain passed the "Crea y Crece" (Create and Grow) law in September 2022. This legislation aims to combat late payments and promote digitalisation by making e-invoicing mandatory for all B2B transactions.

The rollout timeline

While initially expected sooner, the implementation has faced delays pending the approval of final technical regulations. Current expectations place the rollout in 2027 at the earliest, following this likely schedule once the regulations are published:

• Phase 1: E-invoicing becoming mandatory for large companies (annual turnover above €8 million).
• Phase 2: E-invoicing becoming mandatory for all other companies and professionals.

The proposed model mirrors trends seen elsewhere in Europe, likely involving a "hybrid" system. Businesses will be able to exchange invoices via a public solution (managed by the tax authority) or through certified private platforms.

This upcoming mandate presents a massive opportunity for software platforms. By integrating compliant e-invoicing capabilities now, you future-proof your product for the inevitable market shift.

E-invoicing standards and networks 

To ensure interoperability and compliance, Spain relies on specific technical standards.

• Facturae: This is the dominant national standard. It is an XML-based format used for B2G transactions and is expected to play a central role in the B2B mandate as well.
• UBL and CII: To align with European norms (EN 16931), Spain also accepts these standard formats, facilitating cross-border trade.

The role of Peppol

While Facturae is king domestically, the Peppol network is gaining traction, particularly for cross-border transactions and within certain sectors, like healthcare. Peppol offers a standardised way to connect different software systems without building custom point-to-point integrations.

For software providers, support for both Facturae and Peppol is the golden ticket. It ensures your customers can trade seamlessly within Spain’s borders and across Europe.

Tax and compliance considerations

Beyond standard invoicing, Spain has stringent reporting requirements that software vendors must be aware of.

SII (Immediate Supply of Information)

Large companies (turnover >€6 million), VAT groups, and those on the monthly refund register must comply with the SII system. This requires near real-time reporting of invoicing data to the tax authority (AEAT) within four days of issuance or receipt.

Veri*Factu

A new anti-fraud regulation, Veri*Factu, is set to be implemented (likely by 2027 alongside the B2B mandate). It targets billing software specifically.

Systems will need to:

• Generate a unique hash for each invoice to prevent alteration.
• Ensure an audit trail of all transactions.
• Ideally, send records automatically to the tax authority ("Veri*Factu" systems).

This is a critical compliance requirement for ERPs and accounting software. Non-compliant software could expose your customers, and your business, to significant penalties.

TicketBAI (Basque Country)

The Basque Country has its own fiscal system called TicketBAI. It requires invoicing software to generate a unique code and QR code for every invoice, sending the data to the provincial tax authority in real-time. This is already mandatory in the three Basque provinces (Álava, Bizkaia, Gipuzkoa).

Conclusion 

Spain’s e-invoicing landscape is a mix of established mandates and evolving regulations. With the B2G system firmly in place and the B2B mandate on the horizon, businesses across the country are moving towards a fully digital future.

For software vendors, the complexity of regional variations (like TicketBAI) and dual requirements (SII vs. Veri*Factu) can be daunting. But it doesn't have to be a barrier to entry.