Electronic Invoicing in Spain (Ley Crea y Crece)

What Is Electronic Invoicing in Spain?

Electronic invoicing — facturación electrónica — refers to the creation, transmission, receipt, and storage of invoices in a structured digital format that can be automatically processed by accounting and tax systems. It differs from simply scanning a paper invoice or attaching a PDF to an email; a true e-invoice is a machine-readable structured file (XML or similar) that contains all mandatory invoice fields in a standardised schema.

Spain has operated a mandatory e-invoicing system for B2G (business-to-government) transactions since 2015 through the FACe platform. The major legislative step came with Ley 18/2022 of 28 September 2022, known as the Ley de Creación y Crecimiento de Empresas (Ley Crea y Crece), which extended the obligation to B2B (business-to-business) transactions between private sector companies. The implementing regulation (Reglamento) sets out the technical standards and the phased timetable for compliance.

How It Works in Spain

The Two-Platform Architecture

Spain’s B2B e-invoicing framework is built around two complementary mechanisms:

1. Accredited private e-invoicing platforms (plataformas privadas acreditadas): Large companies and platforms that already exchange invoices electronically (via EDI, existing XML integrations, or supplier portals) can continue to do so, provided they meet the technical and legal requirements set out in the Reglamento — including guaranteed delivery, integrity, authenticity, and access for the tax authorities.

2. The public solution (solución pública): The Spanish government is developing a free public e-invoicing platform, accessible to all businesses, particularly SMEs that cannot afford private platform licences. The public solution is based on the Facturae format and integrates with the existing FACe infrastructure.

Mandatory Invoice Fields

An electronic invoice under Spanish law must include all the fields required by the general invoicing regulations (Real Decreto 1619/2012), presented in the structured format:

• Issuer and recipient NIF/CIF and full name/registered address
• Invoice number and date
• Description of goods or services
• Tax base, VAT rate, and VAT amount (broken down by rate)
• Total amount due
• Payment terms and method

Invoices must be signed with a qualified electronic signature or an equivalent mechanism that guarantees authenticity and integrity.

Acceptance Obligation

A key feature of the Ley Crea y Crece is that it is not only an issuing obligation — businesses must also accept e-invoices from their suppliers. Refusing to accept an electronic invoice from a supplier that issues in a compliant format is itself a sanctionable infringement.

Key Regulations

• Ley 18/2022 (Ley Crea y Crece), Article 12: the primary legal basis for B2B e-invoicing
• Real Decreto 1007/2023: the e-invoicing Reglamento, which sets out technical specifications, accreditation of private platforms, and the phased implementation timetable
• Real Decreto 1619/2012: the general invoicing regulations that define mandatory invoice fields and retention requirements
• Directiva 2014/55/UE: EU directive on e-invoicing for public contracts, already transposed in Spain via the B2G framework
• SII (Sistema de Información Inmediata): while technically separate from e-invoicing, the SII and e-invoicing systems share data and complement each other; large companies already within SII scope have head-start technical infrastructure

Practical Implications for Foreign Investors and Companies

Subsidiaries and Branches

A foreign company’s Spanish subsidiary or branch that engages in B2B commercial transactions in Spain must comply within the applicable deadline. This requires:

• Updating ERP or accounting software to generate Facturae/UBL-compliant files
• Enrolling in an accredited private platform or connecting to the public solution
• Updating supplier onboarding processes to request electronic invoice addresses from Spanish counterparties

VAT Reporting Interaction

For companies already enrolled in the SII (Immediate Information Supply) system — which covers businesses with annual turnover above €6 million, VAT groups, and voluntary participants — there is significant overlap. SII requires near-real-time VAT ledger reporting to the AEAT; structured e-invoices make SII data extraction more accurate and reduce the reconciliation burden at year-end.

SMEs and Self-Employed Contractors

Smaller businesses have a longer runway, but should not delay preparations. Connecting to the public platform is free, but aligning internal workflows, training staff, and updating customer contracts to include electronic invoicing clauses all take time. Foreign SMEs with Spanish clients should proactively discuss e-invoicing formats with their Spanish counterparts before the deadline applies.

Data Retention

E-invoices must be retained for a minimum of four years under the general statute of limitations for tax obligations, and up to five years for VAT purposes in certain circumstances. The storage system must guarantee integrity, authenticity, legibility, and accessibility for AEAT inspections.

How BMC Can Help

Our team assists businesses of all sizes — from Spanish subsidiaries of multinational groups to SMEs and freelancers — in assessing their current invoicing workflows and identifying the steps needed to achieve compliance before their applicable deadline. We advise on platform selection, ERP configuration, supplier communication strategies, and the interaction between e-invoicing obligations and the SII reporting system.