Summary
- B2G mandate: No Business-to-Government (B2G) eInvoicing mandate exists, but since 1 January 2015, all public sector entities are required to receive and process structured eInvoices compliant with the European standard EN 16931[2], as mandated by Law 25/2013, which transposes Directive 2014/55/EU. Businesses supplying goods or services to public authorities are encouraged to issue structured eInvoices compliant with the European standard EN 16931 [3], because this guarantees that public authorities must accept these eInvoices.
- B2B and B2C mandates: In September 2022, the Law 18/22 established mandatory national Business-to-Business (B2B) eInvoicing, with a focus on digitalisation and alignment with the European digital transformation agenda.
- eInvoicing standard: The European eInvoicing standard EN 16931 has been adopted in Spain by public authorities. All public contracting authorities in Spain are required to accept and process electronic invoices that comply with the European Standard for eInvoicing for all public procurement contracts above EU Public Procurement thresholds [4]. Private suppliers are not legally required to issue eInvoices under EN 16931.
- Operating model for B2G eInvoicing: The FACe platform is the single-entry point for eInvoicing in Spain. This platform enables the submission and tracking of all eInvoices addressed to thousands of public administrations connected to the system. The use FACe of mandatory for central government and optional for regional and local governments.
- Use of CIUS and Extensions for European Standard for eInvoicing EN 16931: 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.
- VAT Real-time reporting system: A real-time reporting system for eInvoicing is available.
- Monitoring mechanism: 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
No Business-to-Government (B2G) eInvoicing mandate exists, but since 1 January 2015, all public sector entities are required to receive and process structured eInvoices compliant with the European standard EN 16931, as mandated by Law 25/2013, which transposes Directive 2014/55/EU. Businesses supplying goods or services to public authorities are encouraged to issue structured eInvoices compliant with the European standard EN 16931, because this guarantees that public authorities must accept these eInvoices. Additionally, this law establishes FACe (Facilita la Administración de la Comunicación Electrónica) as the single-entry point for receiving eInvoices from suppliers.
B2B
No B2B mandate has been issued yet. However, On February 2, 2024, the Spanish Ministry of Economic Affairs and the Ministry of Finance and Public Function amended the Law 18/2022 . This amendment mandates that all B2B transactions must be conducted using eInvoices. Businesses with annual revenues of EUR 8 million or more must comply within one year, while others have a two-year compliance period
B2C
There is no business-to-consumer (B2C) mandate.
Status on the implementation of the European eInvoicing standard
The implementation of the European standard EN 16931 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).
Operating model for eInvoicing
The FACe platform is the single-entry point for eInvoicing in Spain. This platform enables the submission and tracking of all eInvoices addressed to thousands of public administrations connected to the system. The use FACe of mandatory for central government and optional for regional and local governments. FACe is designed to provide a standardised and efficient eInvoicing process for both public and private sectors.
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.
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.
VAT Real-time reporting system
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.
[1] The European Standard on EU law sets minimum harmonised rules for tenders whose monetary value exceeds a certain amount and which are presumed to be of cross-border interest. More information can be found via: https://single-market-economy.ec.europa.eu/single-market/public-procurement/legal-rules-and-implementation/thresholds_en [2] The European Standard on eInvoicing (EN 16931) defines a common format and data model for electronic invoices, ensuring they are structured, machine-readable, and compatible across EU systems. [3] Ibid.2 [4] The European Standard on EU law sets minimum harmonised rules for tenders whose monetary value exceeds a certain amount and which are presumed to be of cross-border interest. More information can be found via: https://single-market-economy.ec.europa.eu/single-market/public-procurement/legal-rules-and-implementation/thresholds_en
NO VERIFICATION