Spain Publishes draft of ruling for E-Invoicing Regime

Baker Tilly 26 July, 2023

Spain's State Tax Administration Agency has updated the draft Royal Decree for its proposed e-invoicing regime, targeting business-to-business (B2B) transactions involving companies and self-employed entrepreneurs. The e-invoicing regime will adopt a decentralized Continuous Transaction Control (CTC) model. Businesses can choose from various file options, including UBL, Facturae, CII, or EDIFACT for e-invoices. The regime is supported by a public electronic invoicing solution serving as the invoice repository, along with private e-invoice exchange platforms operated by approved agents.


  • The regime's initial launch target of July 2024 is now unlikely due to the absence of detailed technical specifications.
  • Spain needs to obtain permission from the European Commission for enforcing mandatory e-invoicing, which is expected to be a mere formality.

Timeline and deadlines:

  • Large taxpayers (turnover above €8 million) must comply 12 months after the regulations' publication in the Official State Gazette.
  • All other taxpayers have a deadline of 24 months after publication.

Technical requirements:

  • The newly published regulations include technical and information requirements for electronic invoices, such as payment date verification, average payment periods, and interoperability between technology providers.
  • Security, control, and standardization requirements for devices and approved IT or ERP systems generating e-invoices are also outlined.

Submission options:

  • Businesses have several options for submitting e-invoices, including using the Spanish Tax Administration Agency exchange platform, a free app for smaller taxpayers, privately-operated certified e-invoicing agents, or a combination.

Format and Compliance:

  • The Spanish e-invoicing regime aligns with the EU e-invoice Directive, particularly around the EN 16931 structured e-invoice semantic and EU VAT in the Digital Age proposals.
  • The tax authorities reserve the right to impose additional data requirements, and parties involved in e-invoice transactions may agree on additional information.

Private e-invoicing agents:

  • They play a crucial role in ensuring interoperability between different formats.
  • Agents must have the capability to transform invoice messages across all supported formats while preserving authenticity and integrity.
  • The government approves agents based on criteria like interoperability, digital security, and continuity planning.

Exemptions and Recipient Responsibilities:

  • Certain transactions are exempt, such as simplified invoices, cases without statutory invoicing requirements and transactions with non-resident customers or suppliers.
  • Recipients must keep issuers informed of invoice status and payment details within four working days of receiving e-invoices.


  • The mandatory e-invoicing requirement will initially apply to resident Spanish businesses with a fixed establishment starting from mid-2024.
  • Large taxpayers expected to comply from July 2024, while all other businesses mandated to comply by early 2026.

Other Information:

  • The new e-invoicing regime may not replace the existing SII live invoice reporting regime introduced in July 2017.
  • The introduction of mandatory e-invoices aims to improve business efficiency and combat VAT fraud.
  • EU member states plan to implement mandatory e-invoicing for intra-community transactions from 2028.
Baker Tilly International

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