2025 Spain (2025 eInvoicing Country Sheet)

Summary 

• In Spain, Business-to-Government (B2G) electronic invoicing (eInvoicing) has been mandatory since 1 January 2015. 

• In September 2022, the Law 18/22 established Business-to-Business (B2B) eInvoicing as mandatory country-wide, with a focus on digitalisation and alignment with the European digital transformation agenda.  

• The FACe platform is the single-entry point for eInvoicing in Spain, mandatory for central government and optional for regional and local governments.  

• The SII (the immediate electronic reporting system for VAT in Spain) is compulsory for resident and non-resident businesses with an annual turnover above EUR 6 million per year. Businesses required to comply with the SII are exempted from other periodic reporting obligations.  

• The eInvoicing monitoring is ensured via the platform FACe, with data publicly available and continually updated in OBSAE (the public administration observatory). 

Highlights  

The Spanish Ministry of Economic Affairs and the Ministry of Finance and Public Function presented an amendment to the Law 18/2022 on 2 February 2024. The updated law requires all B2B transactions to be exclusively supported by eInvoices, with a one-year or two-year compliance period depending on the total revenues of the business. Businesses with total revenues of 8 million Euros or more per year will have one year to comply. Other businesses will have two years from the enactment of the eInvoicing technical regulations to comply. 

Legislation 

B2G 

 Since 1 January 2015, B2G eInvoicing has been mandatory in Spain. The Law 25/2013 mandates the use of electronic invoices and the creation of an accounting record of invoices in the public sector. Additionally, this law establishes FACe (Facilita la Administración de la Comunicación Electrónica) as the single-entry point for receiving eInvoices from suppliers. Law 25/2013 applies to sub-central bodies as well. The common entry point is publicly available. 

B2B 

No B2B mandate has been issued yet. However, the Law 18/22 (“Crea y Crece”), published in September 2022, established that B2B eInvoicing will become mandatory throughout the country. The Law 18/22 is primarily intended to facilitate the creation and growth of businesses in Spain while also mandating the use of eInvoices in the country. This law established that all businesses, regardless of sector, are required to issue, send, and receive eInvoices when engaging in B2B activities. Moreover, the Law 18/22 indicates that the technical regulations that will provide the specific details regarding the eInvoices should comply with the standards established by EU Commission Implementing Decision (EU)2017/1870 of 17 October 2017 and EU Directive 2014/55 that establish the EU standard for eInvoicing, as well with the local invoicing regulations of Spain. 

On 2 February 2024, the Spanish Ministry of Economic Affairs and the Ministry of Finance and Public Function presented an amendment to the Law 18/2022. The updated law mandates that all B2B transactions must use eInvoices exclusively. The software solutions that taxpayers use to generate, process, and validate these invoices must be approved by the tax administration. Businesses with total revenues of 8 million Euros or more per year will have one year to comply, while other businesses will have two years from the enactment of the eInvoicing technical regulations.  

B2C 

There is no business-to-consumer (B2C) mandate. 

Operating model for eInvoicing   

FACe is mandatory for the central government and optional for regional and local governments. This platform enables the submission and tracking of all eInvoices addressed to thousands of public administrations connected to the system. 

More than 8 000 public administrations use FACe (updated data can be consulted at OBSAE)), including 16 of the 17 autonomous communities, more than 8 000 local governments and all of the public organisations of the General State Administration.  

FACe is designed to provide a standardised and efficient eInvoicing process for both public and private sectors. 

Suppliers can access eInvoicing services through the FACe portal, which provides a web services interface for direct integration of invoice processing applications. The services available include a directory of financial units, discovery of invoice presentation points, submission of eInvoices, as well as monitoring and management of presented eInvoices. 

Public administration suppliers can create eInvoices using compatible invoicing applications, eInvoicing service providers (e.g., banks), or the free eInvoicing client software provided by the Spanish Ministry of Industry. This client software is fully integrated into the FACe platform, making it an attractive option for small and medium-sized enterprises (SMEs) processing low volumes of invoices. The use of specific eInvoicing solution providers is neither mandatory nor recommended; however, SGAD maintains a list of eInvoicing solution providers. 

The open approach of the FACe system has contributed to its success, with over 12 million eInvoices processed annually. This has resulted in considerable savings for both, the public and private sector, due to the use of a fully automated invoicing process. 

Local and regional governments have two options: Develop their own eInvoicing solutions or use a reception system provided by other administrations, with FACe being the system of choice in most cases. The Ministry of Finance Order HAC/1177/2024 outlines the technical, functional, and content specifications for computer or electronic invoicing systems, which came into effect on 29 October 2024.  

As part of the new specifications, invoices must now include a QR code for verification purposes, along with the phrase "Invoice verifiable on the STA website" or "VERIFACTU." Manufacturers and retailers of invoicing software must ensure that their products meet the new specifications by July 2025. Users of electronic invoicing systems must also adapt to the new regulations by 1 July 2025. 

Status on the implementation of the European eInvoicing standard 

 The implementation of the European eInvoicing standard (EN) in public entities is achieved through the FACe platform. For non-domestic suppliers, this platform provides a crucial translation mechanism, allowing public entities to process EN invoices using their current tools and applications, by converting them into the national format (Facturae). 

To further enhance this translation process, a dedicated Core Invoicing Usage Specifications (CIUS) has been developed. This CIUS is designed to apply national regulations and conventions for eInvoicing to the public sector, while also restricting data formats to ensure compliance with the eInvoice national format (Facturae). 

Use of Core Invoicing Usage Specifications (CIUS) at national level  

The Spanish national CIUS is applicable not only at the national level but also at the sub-central level. This allows for a unified and standardised approach to eInvoicing across the country. 

Digital reporting requirements

The use of the SII is compulsory for resident and non-resident businesses with an annual turnover above EUR 6 million per year, as well as businesses registered in the Monthly Refund Register (REDEME scheme) and businesses belonging to VAT groups (joint VAT registration) registered in Spain. The SII can be applied by any VAT payer who chooses to opt in voluntarily. 

Businesses required to comply with the SII are exempted from other periodic reporting obligations, including the submission of third-party transaction forms (347), record books (340), and the annual VAT return (390). 

The scope of requirements foresees that all transactions, regardless of their value, are subject to SII, including B2B, B2G and B2C transactions, domestic transactions, intra-EU transactions, sales, and purchases. 

The reporting frequency is quasi real-time, requiring taxpayers to submit invoice data within four working days following the date of invoice issuance. 

Monitoring mechanism  

The eInvoicing monitoring is ensured via the platform FACe. The monitoring is based on the analysis of the number of invoices that are submitted electronically and submitted in a specific syntax. The data is publicly available and continually updated in OBSAE. 

Next steps 

Effective on 1 January 2026, the VERIFACTU system will become mandatory for all companies that are not subject to the SII Reporting mandate. This will require these companies to use certified accounting software and obtain invoice clearance for all their transactions. 

NO VERIFICATION

Last updated:  Apr 15, 2025 01:03