Electronic invoicing in Spain has moved from being an option to becoming a progressive obligation that will affect all companies and self-employed professionals. This article brings together everything you need to know about the system, timelines and practical steps to adapt in advance.
What is an Electronic Invoice?
An electronic invoice is a billing document issued, transmitted and received in structured electronic format, which can be automatically processed by IT systems. Unlike a PDF — which is merely a digital image of paper — a structured electronic invoice (in Facturae, UBL or PEPPOL format) enables direct integration with accounting systems and ERPs.
This distinction is fundamental: many companies believe they are already issuing electronic invoices because they send PDFs by email. However, a PDF is not an electronic invoice in the legal sense. A true electronic invoice has a structured format (XML or similar) that the recipient’s systems can read and import automatically, without manual intervention.
Regulatory Framework in Spain
The obligation for electronic invoicing in the public sector has existed since Law 25/2013. This law requires Facturae-format electronic invoices for transactions with the Central Government, Regional Governments and Local Councils when the amount exceeds €5,000. The reference platform is FACe (Punto General de Entrada de Facturas Electrónicas), although many regional administrations have their own interoperable platforms.
Law 18/2022 (Crea y Crece) extends this obligation to the B2B sphere. The implementing regulation, which will specify timelines, establishes that companies with more than eight million euros in turnover must adapt in the first year and SMEs in the second. The differentiating element compared to the B2G model is the introduction of the VERI*FACTU system, which not only defines the invoice format but requires the automatic transmission of billing records to the AEAT, creating unprecedented real-time fiscal control in Spanish tax law.
Electronic Invoice Formats in Spain
The main formats used in Spain are:
Facturae (XML): The official format for relations with the Public Administration and the most widely used in Spain. It is defined by the Ministry of Finance and has several versions (3.2, 3.2.1, 3.2.2). It supports XAdES electronic signatures to guarantee document authenticity and integrity.
UBL (Universal Business Language): ISO/IEC 19845 international standard, widely used in Europe — particularly in international commercial relations. Compatible with PEPPOL, the European electronic document exchange network.
PEPPOL: Not a format but a transport network and set of interoperability specifications. It enables invoice exchange between companies in different European countries in a standardized manner. Highly relevant for companies operating in European B2B markets.
Advantages of Early Digitalisation
Adopting electronic invoicing before the obligation enables: reducing management costs (printing, postage, physical archiving); accelerating collections through automatic invoice status tracking; improving accounting reconciliation; and obtaining real-time information on debtor and creditor status.
Data from the European market — where electronic invoicing has been mandatory for longer in countries such as Italy — indicates that the average cost of processing a paper invoice is around €15-20 per document (including receipt, validation, posting, archiving and dispute resolution), compared to €3-5 for an electronically processed invoice handled automatically. For a company receiving 200 invoices per month, the difference exceeds €24,000 annually.
How to Choose a Solution
The market offers everything from complete ERPs with electronic invoicing modules to specific SaaS solutions for SMEs. Selection criteria should include compatibility with required formats, integration with existing systems and total cost of ownership.
For companies with fewer than 100 monthly invoices, a specific electronic invoicing SaaS solution (approximate cost: €30-80 per month) may be more appropriate than upgrading a complete ERP. For companies with higher volumes or complex approval processes, integration into the existing ERP or engagement of an Electronic Invoicing Service Provider (PSE) is the most efficient option.
It is important to verify that the chosen solution meets the AEAT’s VERI*FACTU approval requirements and includes electronic signature functionality, secure transmission and digital archiving with integrity guarantees.
Implementation Checklist
A practical checklist for companies preparing for mandatory electronic invoicing:
- Audit all systems that currently generate invoices (ERP, accounting software, CRM billing modules)
- Identify invoice volumes by type (B2G already mandatory, B2B upcoming)
- Evaluate whether existing software can be updated to comply or must be replaced
- Shortlist AEAT-approved software providers or PSEs
- Review internal workflows for invoice approval and dispatch
- Assess requirements for receiving and processing incoming electronic invoices
- Verify archiving procedures (4-year minimum in electronic format)
- Check eligibility for Kit Digital grants (up to €3,000 for SMEs under 50 employees)
Digitalisation Aid: Kit Digital
SMEs and self-employed professionals who need to invest in electronic invoicing software may be eligible for grants under the Kit Digital programme, funded by Next Generation EU funds. The “Electronic Invoice” category covers invoicing solutions with aid amounts of up to €2,000 for companies with 0-2 employees, €2,000 for companies with 3-9 employees and up to €3,000 for companies with 10-49 employees. We recommend verifying the current call and updated requirements on the Red.es website.
At BMC we help clients choose and implement the most appropriate solution. See our business digitalisation services.
