eInvoicing Documentation
eInvoicing in Spain
Legislation
The Law 25/2013 mandates the use of electronic invoices as well as an accounting record of invoices in the public sector. It also obliges all public entities to receive all invoices through one common point of entry regardless of their different units and departments. This common entry point, FACe, is publicly available.
In accordance with this law and as of 15 January 2015, all invoices sent to the public sector entities must be submitted electronically, should have a structured format (Facturae V3.2.X) and be signed with an electronic signature based on a qualified certificate.
Public administrations shall receive and process invoices electronically; nevertheless, administrations can accept printed invoices under certain circumstances (e.g. if the amount is less than EUR 5 000).
The Law 18/22 is primarily intended to facilitate the creation and growth of businesses in Spain but also mandates the use of electronic invoices in the country. According to the law, all B2B transactions should be exclusively supported by electronic invoices and the software solutions used by taxpayers to generate, process and validate those invoices should be authorized by the tax administration.
- Businesses with total revenues of 8 million Euros or more a year will be required to comply with the mandate one year from the date the electronic invoicing technical regulations are enacted by the central government/tax administration.
- Other businesses will have to start complying with the mandate two years from the date the electronic invoicing technical regulations are enacted by the central government/tax administration.
The law indicates that the technical regulations that will provide the specific details regarding the e-invoices should comply with the standards established by EU Commission Implementing Decision (EU)2017/1870 of October 17, 2017 and EU Directive 2014/55 that establish the EU standard for e-invoicing, as well with the local invoicing regulations of Spain.
eInvoicing platform and eInvoicing management solutions
The General State Administration offers an eInvoicing entry point (FACe) to all public entities as a free of charge service. The use of FACe is mandatory for the central government and optional for regional and local governments. FACe enables the submission and tracking of 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, the public administration observatory), including 16 of the 17 autonomous communities, more than 8 000 local governments and all of the public organisations of the General State Administration.
Public administration suppliers are free to choose their eInvoicing solution. The electronic invoicing platform FACe can be accessed through open, public and free automated interfaces; which has created a dynamic market of private solutions with high added-value to allow large companies, the entire banking sector, and many SMEs to provide electronic billing services integrated with the platform. The use of specific eInvoicing solution providers is neither mandatory nor recommended. Nevertheless, SGAD maintains a list of eInvoicing solution providers, all of which fulfill the following conditions: they are connected to FACe through the automated interface of web services available to suppliers and they have submitted electronic invoices through the mentioned interface.
FACeB2B is a platform (available since June 2018) allowing B2B electronic invoicing. It is provided by the government, it is free of charge for any business and it uses the same format and interfaces already in place for B2G invoicing.
Approach for receiving and processing eInvoices
FACe is the single-entry point of eInvoices for central government. Local and regional governments can either develop their own solutions or use a reception system provided by other administrations. In most cases the system of choice is FACe. Suppliers can retrieve ‘eInvoicing addresses’ of any public administration (even those not connected to FACe) using the directories and query services available in the FACe portal. All eInvoice reception systems are integrated with the Accounting Register of Invoices, which acts as a centralised mechanism of the payment process control.
Electronic invoicing services provided by FACe can be accessed through the platform’s portal. A web services interface is also provided in order to support direct integration of invoice processing applications. Its services include: directory of financial units and discovery of invoice presentation points, submission of eInvoices and tracking and management of presented eInvoices. Public administration suppliers can create eInvoices using any compliant invoicing application; using an eInvoicing service provider (e.g. banks); or, especially in the case of SMEs processing low volumes of invoices, using the free eInvoicing client software provided by the Spanish Ministry of Industry. This free eInvoicing client software is fully integrated into the FACe platform through the aforementioned web services interface.
This open approach has contributed to the success of eInvoicing in Spain. The FACe system processes more than 12 million eInvoices annually (updated information is available in OBSAE), providing considerable savings for the public and private sectors due to the use of a fully automated invoicing process.
Following up on Law 18/2022, Spain is currently working to determine the technical and information requirements to be included in electronic invoicing, which will be established within a period of 6 months from the publication of the law (29 September 2022) for all B2B transactions.
eInvoicing implementation in sub-central level contracting authorities
At sub-central level, more than 8 000 contracting authorities use FACe, the centralised platform provided by the government. For non-domestic suppliers, the centralised platform actions a "translation" between formats. Law 25/2013 applies to sub-central bodies as well.
The Spanish national CIUS is also applicable at the sub-central level. The communication about this CIUS is ensured through the updated CEF community-driven registry.
The onboarding actions to public authorities and SMEs are done through the FACe platform offering B2G sub-central and B2B and the intervention of the National Forum.
The main identified benefits of the implementation of eInvoicing at the sub-central level are cost and operational savings, the reduction of administrative burden and optimisation of time to payments and the contribution to process automation.
Status on the implementation of the European Standard on eInvoicing (EN)
The implementation of EN in public entities is accomplished through FACe, the single entry point for eInvoices. This platform provides a translation mechanism to the national format (Facturae) allowing any public entity to process EN invoices with the current set of tools and applications available.
In order to strengthen this translation process a dedicated CIUS has been developed applying national regulations and conventions for eInvoicing to the public sector and restricts data formats in compliance with the eInvoice national format (Facturae).
Monitoring eInvoicing implementation
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.
Additional information
The Electronic Invoice Forum is responsible for the management of eInvoicing at national level. It includes representatives from both the private and the public sectors. Its responsibilities include:
- Monitoring and analysis of the current situation of eInvoicing;
- Identification of opportunities for improvement and progress towards the full adoption of an eInvoicing in public procurement;
- Promotion of the collaboration of public and private sector organisations in the harmonisation of the technical and functional requirements for eInvoices;
- Ensure that eInvoicing becomes a reality throughout the Spanish public sector;
- The decisions made at meetings of the Electronic Invoice Forum are publicly available at https://administracionelectronica.gob.es/comunidades/forofacturae
Digital reporting requirements
In Spain, the Suministro Inmediato de Informacion (SII) is the immediate electronic reporting system for VAT in Spain. The use of SII is compulsory for resident and non-resident businesses which are VAT-registered in Spain, with an annual turnover above EUR 6 million per year, 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 the third-party transactions form (347), record books (340) and the annual VAT return (390).
The scope of requirements foresees that all transactions regardless of their value for B2B, B2G and B2C domestic and intra-EU transactions sales and purchases.
In addition, the reporting frequency is quasi real-time. Taxpayers must submit invoice data within four working days following the date of the invoice issuance.
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