In April 2025, the Spanish Ministry of the Economy concluded a second public consultation regarding the proposed regulations for the forthcoming Draft Royal Decree known as Crea y Crece, which is set to mandate e-invoicing.
The draft regulations include several significant updates:
Currently, no technical specifications have been published, which would necessitate further public consultation. Consequently, the implementation date remains uncertain but must allow at least a 12-month notice period once the final regulations are published, making it unlikely to occur before 2027.
The implementation of the e-invoicing system will occur in two phases, contingent on a 2027 start date:
Additionally, a requirement for certification of VERIFACTU electronic invoicing software for smaller businesses is anticipated for implementation in January 2026.
On May 6, the European Commission supported Spain's legislative efforts (Real Decreto de desarrollo de la Ley 18/2022) to mandate B2B e-invoicing. The Commission's feedback was a response to Spain’s request to deviate from the EU Directive to prioritize e-invoices over paper invoices. The report indicated that Spain's legislation does not infringe upon EU law.
The Commission's comments pertained mainly to proposed language regarding digital signatures and the inclusion of 'seals' to cover invoices issued by legal entities. While Spain still lacks the necessary EU approval to enforce mandatory e-invoicing, the EU's own ViDA Digital Reporting Requirements proposals are considering the withdrawal of this necessity, subject to approval by EU Finance Ministers. Spain may also prefer to await further details on the ViDA proposals regarding inter-community e-invoicing and digital reporting requirements, expected to be finalized by July 2030, before progressing with its domestic e-invoicing system.
Spain's State Tax Administration Agency has revised the draft Royal Decree outlining its proposed VAT e-invoicing regime applicable to B2B transactions involving companies and self-employed entrepreneurs. The current draft includes limited specifications for e-invoice formats.
Spain has adopted a decentralized Continuous Transaction Control (CTC) model, offering several file format options: UBL, Facturae, CII, or EDIFACT. This approach will be supported by both a public electronic invoicing solution, which serves as an invoice repository, and private e-invoice exchange platforms operated by approved agents.
The updated publication outlines the technical and informational requirements necessary to verify payment dates and ascertain average payment periods. It also sets minimum interoperability standards between electronic invoice technology providers and stipulates security, control, and standardization requirements for systems that generate e-invoices.
E-invoices may be submitted through various channels, including:
Spain will require the inclusion of QR codes on invoices to facilitate digital tracking. Furthermore, the Royal Decree will mandate that software developers and retailers ensure their accounting systems are compliant with the new e-invoicing requirements and capable of transmitting the necessary data to tax authorities.
The Spanish e-invoicing regime will align with the EU e-invoice Directive, based on the EN 16931 structured e-invoice semantics, as part of the EU VAT in the Digital Age proposals. The tax authorities reserve the right to enforce additional data requirements, including payment information, while parties engaged in e-invoicing transactions may agree to include further informational requirements.
E-invoices may be structured using one of the following formats:
To ensure interoperability among the various formats, private operators must have the capability to convert invoice messages across different supported formats while maintaining the authenticity and integrity of the invoice content. Agents will be required to connect to each other's reporting platforms upon request and will be approved based on interoperability, digital security, and continuity criteria.
The private operator is responsible for attaching a unique digital signature to e-invoices before sending them to the customer and tax authorities, including:
Certain transactions are exempt from these regulations, including:
Recipients of e-invoices must inform the issuers about the status of any issued invoice. These updates include:
This information must be communicated to the recipient within four working days of receiving the e-invoice.
In September 2022, Spain's lower House of Parliament, the Congress of Spain, ratified a technical specification bill to launch mandatory B2B e-invoicing with pre-clearance through the AEAT, the state tax agency. This bill was published on September 29, 2022, with the government given six months to issue the technical specifications and regulations.
The new mandate will apply exclusively to resident Spanish businesses with a fixed establishment, starting mid-2024, while B2G e-invoicing has already been mandated for invoices exceeding €5,000.
With potential EU VAT reforms, Spain's initiatives include establishing a framework for harmonized Digital Reporting Requirements (DRR) and Continuous Transaction Controls (CTC) among EU member states, encompassing mandatory e-invoicing for intra-community transactions beginning in 2028.
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 the 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 Spanish 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 an SAP partner for PE services and an 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