Issued by the Ministry of Economic Affairs and Digital Transformation, this consultation aims to engage industry stakeholders and citizens alike, enhancing key elements of the Royal Decree established under Law 18/2022, known as "Crea y Crece." It is essential for all businesses in Spain, large corporations and small to medium-sized enterprises (SMEs), to understand these developments to prepare for compliance effectively.
Key Modifications and Explanations from the Second Consultation
Adoption of Universal Business Language (UBL)
The formal acceptance of UBL as the required electronic invoice format for transactions within the public electronic invoicing system represents a significant shift, aligning Spain with the European standard EN16931. This move signifies a departure from the previously used Facturae format.
Introduction of 'Faithful Copy'
The consultation clearly defines the concept of a "faithful copy." Each invoice generated through private or public invoicing systems must simultaneously provide a faithful digital copy in UBL format to the central public electronic invoicing platform managed by the AEAT.
Elimination of Voluntary E-Invoicing Exemption
The updated consultation removes the prior exemption for voluntary electronic invoices. As a result, all B2B invoices—including those that were previously voluntary—are now subject to the electronic invoicing requirement.
Compulsory Implementation Timeline
A crucial clarification states that the mandatory implementation of electronic invoices for B2B transactions will take effect one year after the ratification of the Ministerial Order that outlines the public e-invoicing platform. This establishes clear timelines for businesses:
Large Enterprises (turnover exceeding €8 million): 1 year post ratification of the Ministerial Order.
Small and Medium-Sized Enterprises (turnover below €8 million): 2 years post ratification.
Supported Formats
UBL (Universal Business Language) is the primary format required for interoperability with the public platform, ensuring compliance with the European standard EN16931. The Facturae format, which has historical significance in Spain, remains valid for private networks. Additionally, CII (Cross Industry Invoice) is suitable for businesses operating extensively across Europe or internationally, while EDIFACT is frequently used by larger corporations with established Electronic Data Interchange (EDI) systems.
Spain's revised regulations aim to align with broader EU digital tax reporting initiatives, particularly the VAT in the Digital Age (ViDA). This alignment facilitates international businesses by standardizing compliance requirements across the European market.
How Can KGT Support You?
KGT has created an SAP-integrated e-invoicing add-on solution for Spain, featuring outbound and inbound functionalities to meet tax reporting requirements. This add-on includes a data extractor and a cockpit for generating periodic electronic invoices in the legal format and controls before submission. When SAP DRC launched Spanish e-invoicing solution as part of its e-document offerings, KGT emerged as a leading consultancy firm for SAP DRC and tax services. Recognized as an SAP DRC partner for Polish e-invoicing services, KGT is one of SAP's recommended implementation partners for this solution. We provide comprehensive support, including installation, configuration, customization, and training, to help you maximize the long-term value of your SAP DRC investment.
KGT is a SAP partner for PE services and SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at: https://partnerfinder.sap.com/profile/0001925409
The link provided allows you to download KGT's brochure, which offers a detailed explanation of the legal updates and information on how KGT can assist you in meeting these new requirements on time.
If you have any questions, please feel free to contact us. You can submit your inquiries in Spanish, as KGT has local staff to assist you.
