B2B Electronic Invoicing in Spain

Overview of Electronic Invoicing in Spain

Spain is implementing one of Europe’s most comprehensive mandatory B2B electronic invoicing systems, driven by two objectives: reducing the VAT gap (undeclared transactions) and accelerating payment times for SMEs. The regulatory journey has been long and has involved multiple delays, but the requirements are now firmly in place.

The key legislative instruments are:

• Ley 56/2007 de Medidas de Impulso de la Sociedad de la Información: First established e-invoicing rights for large suppliers to public administrations.
• Orden EHA/962/2007 and subsequent regulations: Technical specifications for FacturaE (the public sector e-invoice format).
• Ley 25/2013: Made e-invoicing mandatory for all suppliers to Spanish public administrations (using FACe platform).
• Ley 18/2022 (Ley Crea y Crece): Extends mandatory e-invoicing to B2B transactions between private businesses.
• Reglamento de facturación (pending final approval): The technical regulation implementing the Ley Crea y Crece B2B mandate, including Verifactu specifications.

The Ley Crea y Crece: B2B E-Invoicing Mandate

Ley 18/2022 de Creación y Crecimiento de Empresas (informally “Ley Crea y Crece”) includes a provision requiring all Spanish businesses — including self-employed workers (autónomos) — to issue and receive invoices in electronic format for transactions with other businesses and professionals.

Implementation Timeline

The timeline has been revised multiple times. As of 2026, the expected implementation schedule is:

• Large companies (turnover > EUR 8 million): From 2025 (in line with Verifactu early adoption deadline)
• SMEs and autónomos (turnover ≤ EUR 8 million): From 2026 (12 months after publication of the technical regulation)

Businesses should check the current status of the technical regulation publication with their advisors, as the timeline has shifted.

Who Must Comply?

All businesses and professionals established in Spain who carry out B2B transactions (i.e., transactions between businesses subject to Spanish invoicing regulations). Exemptions may apply to certain specific transaction types (consumer-to-business, transactions below minimum thresholds), but the general rule is universal application.

Verifactu: The Spanish Anti-Fraud Invoice System

Verifactu (Verificación de Facturación) is a complementary system to B2B e-invoicing, focused on anti-fraud controls for the invoicing process. The Verifactu regulation (Royal Decree 1007/2023, effective from 2025) requires:

• Certified invoicing software: Billing software must be certified or declared compliant with Verifactu specifications
• Immutable records: Invoices must be recorded in a tamper-proof way — once issued, they cannot be altered without a visible trace
• Real-time submission (optional) or batch submission: Companies can optionally submit invoice data to the AEAT in real-time (envío inmediato) or maintain records available for AEAT access on demand
• QR code on invoices: All invoices must include a verification QR code that customers can use to confirm the invoice was properly registered

Verifactu is distinct from but complementary to the B2B e-invoicing mandate: Verifactu applies to the invoicing system itself; B2B e-invoicing applies to how invoices are exchanged between parties.

The FacturaE Format

FacturaE (www.facturae.gob.es) is the technical XML format used for electronic invoices in Spain — originally developed for public administration invoicing and now being adapted for B2B use. FacturaE is compatible with the EU’s European standard EN 16931 for electronic invoicing, ensuring cross-border interoperability.

Key technical components of FacturaE:

• XML structure: Machine-readable format that allows automated processing and verification
• Digital signature: Each invoice must be digitally signed with a qualified electronic certificate (certificado electrónico) to ensure authenticity and integrity
• Transmission channels: FacturaE invoices are exchanged through accredited platforms (plataformas de facturación electrónica acreditadas)

Electronic Invoicing for Public Sector Suppliers

For companies already supplying to Spanish public administrations, B2B e-invoicing is not new:

• FACe (Punto General de Entrada de Facturas Electrónicas) is the national portal for submitting electronic invoices to the central government
• FACeB2B is the platform for interadministrative invoicing
• Each autonomous community may have its own supplementary platform (e.g., e.FACT in Cataluña)

Companies supplying public authorities must already issue FacturaE format invoices. The Ley Crea y Crece extends this requirement to all B2B transactions.

Benefits of Electronic Invoicing

For Businesses

• Faster payment: Automated processing removes delays in invoice approval; the Ley Crea y Crece also tightens payment terms to 30 days for B2B transactions
• Reduced cost: Estimated savings of EUR 25–50 per invoice compared to paper (printing, postage, manual processing, archiving)
• Automated accounting: Electronic invoices in structured format feed directly into accounting systems, reducing manual data entry
• Improved cash flow visibility: Real-time tracking of invoice status (sent, received, approved, paid)
• Compliance: Automatic audit trail for VAT and invoicing obligations

For Tax Authorities

• Near real-time data: AEAT gains visibility into business transactions, reducing the VAT gap estimated at EUR 7–8 billion annually in Spain
• Automated checks: Cross-referencing buyer and seller records to identify discrepancies

How to Prepare Your Business

Step 1: Assess Current Invoicing Systems

Determine whether your current billing software is Verifactu-compliant or will be updated to compliance by the deadline. Providers of widely-used Spanish software (Holded, Sage, A3, FacturaPlus, Contasol) are updating their products.

Step 2: Obtain a Qualified Electronic Certificate

All electronic invoices must be digitally signed. If your company does not already have a qualified electronic certificate (certificado electrónico) from an accredited certification authority (Fábrica Nacional de Moneda y Timbre — FNMT, or private providers), obtain one.

Step 3: Update Contracts and Payment Terms

Review supplier and customer contracts for any provisions that specify paper invoicing. Update them to explicitly permit electronic invoicing. Communicate the change to your commercial relationships.

Step 4: Configure Accounting Integration

Maximise the benefit of electronic invoicing by ensuring that your accounting software can receive and process incoming electronic invoices automatically — reducing accounts payable processing time and improving data quality.

Step 5: Archive Compliance

Spanish law requires invoices to be retained for a minimum of 4 years (tax compliance) or 6 years (commercial law). Electronic invoices must be archived in a way that ensures their integrity and authenticity over the retention period. Cloud-based document management systems with immutable audit trails are recommended.

Electronic Invoicing and IVA (VAT) Reporting

Spain’s near-real-time IVA reporting system — SII (Suministro Inmediato de Información) — already requires large companies to submit VAT ledger data within 4 days of invoice issuance. The B2B e-invoicing mandate will eventually create a unified data flow where invoice issuance and SII reporting are a single automated process.

Frequently Asked Questions

Is a PDF invoice an electronic invoice? No. A PDF invoice is not a structured electronic invoice — it cannot be processed automatically by the recipient’s accounting system. A true electronic invoice is an XML file (such as FacturaE) that contains structured, machine-readable data. PDFs are acceptable for SMEs under transitional arrangements but are not the target format under Ley Crea y Crece.

What happens if a business refuses to accept my electronic invoice? Under the Ley Crea y Crece, recipient businesses will be legally required to accept electronic invoices in the approved format. Refusing to accept a compliant electronic invoice will constitute a breach of the law.

Does the e-invoicing mandate apply to foreign companies invoicing Spanish customers? The mandate applies to invoicing obligations under Spanish law — i.e., transactions where the seller is established in Spain. Foreign companies invoicing Spanish customers from abroad are not subject to the Spanish B2B e-invoicing mandate, but they remain subject to Spanish IVA (VAT) obligations where applicable.

Are there fines for non-compliance with the e-invoicing requirement? Yes. The Ley Crea y Crece establishes that failure to comply with the e-invoicing obligation is a commercial law infringement, subject to fines. The AEAT can also impose tax penalties for invoicing infractions under the Ley General Tributaria.

What is the difference between Verifactu and SII? SII (Suministro Inmediato de Información) is a reporting system — companies submit VAT ledger data to the AEAT in near real-time. Verifactu is an invoicing system integrity mechanism — it ensures that invoicing software cannot be manipulated to issue unregistered invoices (a common form of tax fraud). Both are anti-fraud tools, but they operate at different stages of the invoicing and reporting cycle.

How BMC Can Help

We advise Spanish and foreign-owned businesses on B2B electronic invoicing compliance: assessing readiness, selecting and implementing compliant software, obtaining electronic certificates, updating internal processes, and ensuring integration with accounting and VAT reporting systems.