Mandatory electronic invoices in Spain (B2B and B2G e-invoicing guide)

Electronic invoicing, or e-invoicing, has become a significant component of financial transactions in Spain with over 12 million e-invoices processed annually. With B2G electronic invoicing mandatory since 2015, business-to-business electronic invoicing will follow in the near future.

Intending to streamline processes and improve efficiency, Spain joins many EU countries such as Serbia, Poland and Italy in implementing various initiatives and platforms to promote the adoption of e-invoicing. These include FACe, FACeB2B, and the mandatory use of electronic invoicing for certain transactions.

Latest news

The latest Royal Decree on e-invoicing has been published along with an opportunity for companies to provide feedback by 10 July 2023. Due to the limited amount of published information on the technical specifications of e-invoicing, the predicted implementation date of July 2024 is likely to be delayed.

E-invoicing timeline

• January 15, 2015 - For B2G e-invoicing, it is mandatory to submit them electronically and ensure they are signed with an electronic signature utilizing a qualified certificate

  • Exception: printed invoices accepted for contracts less than €5,000

• September 2022 - Spain approved the Crea y Crece Law

• Fall 2024 (or 1 year after approval of technical regulation) - Mandatory B2B e-invoicing for large taxpayers with an annual turnover of at least €8 million

• Fall 2025 (or 2 years after approval of technical regulation) - Mandatory B2B for whose invoices total turnover is less than €8 million

Requirements for B2B e-invoicing in Spain

Electronic invoicing in the B2B sector is not yet required, but starting in 2024 they are forecasted to be mandatory. Companies who wish to try out the system and see the many benefits e-invoices can bring to their business, can voluntarily transmit them through the following steps:

1. FacturaE - XML-based format

This standardized format is the only way of sending compliant invoices. It is an XML-based electronic format and uses the Universal Business Language (UBL) standard.

2. Platform FACe

The Ministerio de Hacienda y Función Pública manages the e-invoicing platform FACe for B2G e-invoices and is the only way to correctly send them to public entities except for those with a contract value of less than €5,000.

3. Platform FACeB2B

While mandates are not yet in place for business-to-business transactions, companies can voluntarily start using the platform to prepare. To register, companies must:

1. Register with DIRe - the Directorio de Entidades gives each company its unique alphanumeric code which it requires to receive electronic invoices

2. Register with FACeB2B - do so with the code from DIRe

3. Authorize an Invoicing Services Company - to access the platform through your ERP and download e-invoices

4. VAT Number

All VAT-liable entities must include their VAT number on all types of invoices.

5. Archiving

Every issued invoice must be stored for 6 years. Clients can maintain access to e-invoices, free of charge for up to 4 years after their issuance.

6. Identification Number

Every Spanish business also has a Número de Identificación Fiscal (NIF) which is a unique identification number which should be included in all invoices

7. E-invoicing Software

Your invoicing system provider must also meet specific requirements to maintain compliance:

• Create invoices in FacturaE format

• Connect to and transmit invoices through the FACe platform

• Sign invoices with an electronic signature

E-invoicing Steps

Crea y Crece Law for mandatory B2B electronic invoicing

The Spanish government published the Crea y Crece law is the law for the creation and growth of companies in Spain through a new electronic invoicing mandate.

The regulation sets a 6-month timeframe for the tax authorities to define the technical and informational requirements regarding electronic invoices after the law is published. Once these regulations in Spain are published, companies will have different implementation deadlines based on their annual turnover.

For companies with an annual turnover exceeding 8 million euros, the implementation deadline is 1 year from the approval of the technical regulations. For companies with a turnover below 8 million euros, the implementation period extends to 2 years from the approval date.

Additionally, recipients have the right to request copies of the invoice for four years from its issuance without any additional cost.

In summary, the law establishes timelines for implementation and ensures that recipients can obtain copies of invoices for a specified period. This law is still in the draft stage and will be updated in the future.

FACe - Punto General de entrada de Facturas Electrónicas

FACe is a platform developed by the Spanish government to exchange electronic invoices between businesses and public administrations. It serves as a centralized system where companies can submit them to various public sector entities, such as government agencies, local authorities, and public corporations.

One of the key features of FACe is its interoperability, which allows invoices to be sent and received in different formats, such as FacturaE, UBL, and other common standards. FACe validates and registers the invoices, ensuring their integrity and compliance with legal requirements.

Spanish e-invoicing for business-to-business transactions will be conducted through a similar platform called FACeB2B through which VAT-registered entities will be able to issue and receive invoices.

Penalties

Companies that fail to provide users with the option to receive electronic invoices or do not maintain access to electronic invoices for individuals who are no longer customers may face a warning or penalty, which can range up to a maximum of €10,000.

Using an electronic invoicing system provider

By utilizing a third-party electronic invoicing service provider, you can have guaranteed tax compliance through API integration into your current invoicing software and avoid penalties. Through their services, you are offered an easy-to-use web interface through which you can send, receive, download and archive your e-invoices.

Steps for e-invoicing through a software provider

1. Export the invoice

This is the first step in the process which is done through the exportation of an invoice in PDF or XML format from your accounting software to your e-invoicing provider.

2. Send the invoice

The software provider then converts the document into specific e-invoicing requirements such as FacturaE. The system then sends it to the client through the FACeB2B platform. The recipient can be confirmed by inputting their DIRe code to check availability.

3. Recipient status

Once a business issues electronic invoices to a recipient, your provider will update your software with the status. You can easily see if the e-invoice was received, accepted, or rejected by the buyer. Transparency is key, and your provider should allow you to view the invoice status directly on your ERP system.

How DDD Invoices can help

DDD Invoices simplifies electronic invoicing in Spain by providing a solution that integrates into your existing software through a single API. This allows companies to automate the invoicing process and satisfy VAT e-invoicing rules in Spain on the FACe platform. We handle e-invoice creation, distribution, and archiving, allowing you and your clients to send and receive e-invoices seamlessly within your existing software.

We stay up to date with local tax regulations so you don’t have to. Mandatory e-invoicing compliance in Spain will become a breeze and if we do not currently serve a territory where you require e-invoicing, let us know, and we can develop it in 2-3 weeks. This way, we can ensure VAT compliance at all times, wherever you do business.

FAQs about e-invoicing requirements in Spain