Mandatory electronic invoicing between companies and professionals in Spain, established in Law 18/2022 on business creation and growth (the "Crea y Crece" Law), marks a fundamental change in companies' administrative management. The implementing regulation, pending final approval during 2023, will specify the timelines and technical requirements for implementation.
Expected Timelines and Current Regulatory Status
According to regulatory forecasts, large companies (turnover exceeding eight million euros) will have one year from the regulation’s approval to adapt. SMEs and self-employed individuals will have two years. The goal is for all B2B transactions in Spain to be conducted via electronic invoice by 2025-2026.
Unlike the electronic invoicing obligation with the Public Administration (in force since Law 25/2013 for contracts above €5,000), which uses the FACe platform and the Facturae format, the new B2B obligation introduces the VERI*FACTU system. This adds an additional layer of fiscal control through the automatic, near-real-time transmission of billing records to the AEAT.
Technical Requirements of the VERI*FACTU System
Electronic invoices must be issued in structured format (XML/Facturae or UBL) and comply with the VERI*FACTU system requirements to guarantee data integrity. The system will automatically send billing records to the AEAT, bringing Spain closer to the real-time e-reporting model already operating in countries such as Italy (SDI system) and Mexico (CFDI).
The essential technical requirements of VERI*FACTU include: the generation of a hash or digital fingerprint of each billing record to guarantee its integrity; electronic signature of issued invoices; secure transmission to the AEAT via the enabled web services; and maintenance of an event log documenting any modification or cancellation.
Invoicing software used by companies must be approved by the AEAT to comply with these technical requirements. This means that not every management program or spreadsheet will be suitable for issuing invoices under the new system.
Differences from the SII (Immediate Supply of Information)
It is important to distinguish the VERI*FACTU system from the SII, already in force for companies with a volume of operations exceeding six million euros and those registered in the Monthly VAT Refund Register. Both systems share the objective of improving the AEAT’s tax control capability, but with different approaches.
The SII requires the supply of VAT register books (issued invoices, received invoices, investment goods) within four working days following the transaction. VERI*FACTU, by contrast, acts at the moment of invoice issuance, creating an unalterable copy at the AEAT. Companies already subject to the SII will have a specific transition regime to avoid duplication of obligations.
Steps to Prepare
Companies must audit their current management systems to determine compatibility with the required formats. If not compatible, they must choose between updating existing software, contracting a SaaS electronic invoicing solution or integrating with an electronic invoicing service provider (PSE).
The preparation process should follow these stages: first, an inventory of current management systems that generate invoices (ERP, accounting software, CRM with invoicing module) and assessment of their compatibility with new requirements; second, selection of the most appropriate approved software or PSE according to invoice volume and process complexity; third, adaptation of internal workflows to incorporate the new electronic signature and transmission steps; and fourth, training of staff involved in invoicing processes.
Companies with high invoice volumes (more than 500 per month) will benefit particularly from automation through a solution integrated with their ERP. SMEs with lower volumes can opt for specific SaaS electronic invoicing solutions, whose cost typically ranges from €30 to €80 per month depending on invoice volume and included features.
Receiver Obligations: Not Just Issuance
A frequently overlooked aspect is that the Crea y Crece Law does not only oblige companies to issue electronic invoices — it also requires them to be in a position to receive and process them. This means companies must have an electronic mailbox for invoice receipt, internal processes for their validation and automatic posting, and archiving systems that meet legal retention requirements (at least four years in electronic format).
The obligation to accept electronic invoices from suppliers has implications for purchasing and accounts payable departments, which must adapt their approval and payment workflows to handle documents in structured format rather than PDFs or paper.
Opportunities from Digitalisation
Early preparation enables leveraging digitalisation to automate reconciliation processes, reduce errors and improve cash flow control. Companies that adopt electronic invoicing ahead of the obligation report an average reduction of 60-80% in invoice management time, thanks to the elimination of manual tasks such as printing, postal dispatch, physical archiving and manual data entry into the accounting system.
Additionally, real-time access to the status of each invoice — issued, received, accepted, paid — enables significantly more efficient working capital management and reduces the average collection period. For a company with €100,000 in monthly billings, reducing the average collection period from 45 to 30 days releases approximately €50,000 in cash, with corresponding financial savings.
At BMC we advise clients on the process of adapting to electronic invoicing. See our accounting and digitalisation services.
