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Spain Advances ViDA Transposition: Cabinet Approves Bill Reforming the OSS Special Schemes

On June 16, 2026, Spain's Council of Ministers (Consejo de Ministros), on a proposal from the Ministry of Finance (Ministerio de Hacienda), approved in second reading the draft bill amending Law 37/1992 on Value Added Tax to partially transpose Council Directive (EU) 2025/516 of March 11, 2025 — the "VAT in the Digital Age" (ViDA) Directive. The bill now moves to the Congress of Deputies (Congreso de los Diputados) for parliamentary debate.

Background

The transposition forms part of the European Commission's VAT Action Plan, first presented in 2016 to modernize the EU VAT system for an increasingly digital economy. The plan's first phase took effect on July 1, 2021, with the e-commerce package that introduced the Union One Stop Shop (OSS) and the Import One Stop Shop (IOSS), and expanded the pre-existing non-Union scheme — which had operated as the non-Union Mini One Stop Shop (MOSS) since 2015 — into the non-Union OSS, shifting VAT collection to the member state of the consumer and significantly reducing multi-country VAT registration burdens.

Council Directive (EU) 2025/516, adopted on March 11, 2025 and published in the EU Official Journal on March 25, 2025, deepens this reform. It amends Directive 2006/112/EC in three areas: combating intra-Community VAT fraud through near-real-time digital reporting based on structured e-invoicing; reducing administrative and registration burdens through a Single VAT Registration; and extending deemed-supplier obligations to digital platforms in sectors such as short-term accommodation rental and passenger transport (short-term accommodation being defined as uninterrupted rental of up to 30 nights).

The Legislative Change

The bill approved on June 16, 2026 addresses the technical, near-term elements of ViDA — specifically, the provisions of the Directive that take effect on January 1, 2027 — rather than its most far-reaching measures. Having completed public hearing and information procedures and received the binding opinion (dictamen) of the Council of State, the Proyecto de Ley now proceeds to Congress.

  • Extension of the scope of the non-Union OSS scheme to cover services supplied to consumers not established in the European Union.
  • A new requirement for non-EU taxable persons who reclaim VAT incurred under the special schemes to appoint a representative (representante) in Spain.
  • Various minor technical adjustments intended to improve the day-to-day functioning of the Union, non-Union, and Import OSS regimes.

Scope

The bill applies to businesses using Spain's implementation of the EU's three special OSS schemes for cross-border B2C supplies, and specifically to non-EU established suppliers and to any business reclaiming VAT through these mechanisms. It is separate from, and should not be confused with, Spain's parallel domestic B2B e-invoicing mandate under the Crea y Crece law and the VeriFactu certified-invoicing regime, which follow their own independent timeline.

Timeline

  • June 16, 2026 — Council of Ministers approves the bill in second reading; referred to the Congress of Deputies.
  • 2026 (ongoing) — Parliamentary debate and possible amendment in the Congreso de los Diputados and the Senate.
  • January 1, 2027 — Technical OSS amendments contained in this bill are scheduled to take effect.
  • July 1, 2028 — Single VAT Registration takes effect: the OSS is extended to cover cross-border transfers of a business's own goods (phasing out the call-off stock simplification), and a domestic reverse charge becomes mandatory for supplies made by taxable persons not established, and not identified for VAT, in the Member State where the tax is due. The platform-economy deemed-supplier rules for short-term accommodation and passenger transport also begin on this date, on an optional basis for Member States.
  • January 1, 2030 — The platform-economy deemed-supplier rules become mandatory in all Member States (having been optional for Member States from July 1, 2028).
  • July 1, 2030 — Digital Reporting Requirements (DRR) and mandatory structured e-invoicing for cross-border B2B transactions take effect. These are the most far-reaching ViDA measures and will require further Spanish transposing legislation.

Businesses Affected

  • Non-EU businesses supplying digital or other services to EU consumers under the non-Union OSS scheme.
  • Businesses established outside the EU that reclaim Spanish or EU VAT via the special schemes and will need to appoint a Spanish fiscal representative.
  • E-commerce sellers, marketplaces, and platforms using the Union or Import OSS schemes for cross-border sales into Spain.
  • Multinational groups already planning for the 2028 and 2030 ViDA milestones, for which this bill is an early, technical first step.

Required Actions

  • Assess exposure under the expanded non-Union OSS scope, particularly for services supplied to non-EU-established customers.
  • Identify and engage a fiscal representative in Spain ahead of the January 1, 2027 effective date if VAT refunds are claimed through the special schemes.
  • Track the bill's progress through the Congreso de los Diputados, since parliamentary debate may introduce amendments before final enactment.
  • Begin scoping the 2028 and 2030 ViDA milestones now, even though the detailed Spanish transposing measures for digital reporting and the platform economy are still pending.

Practical Implications

The immediate compliance burden is administrative: appointing and onboarding a fiscal representative, andupdating OSS registration data to reflect the widened non-Union scheme scope. In SAP landscapes, this typically means reviewing VAT registration master data, partner functions for fiscal representation, and OSS reporting configuration well ahead of the January 2027 go-live.

Because Spain is running its domestic e-invoicing mandate (Crea y Crece/VeriFactu) and its ViDA transposition on separate legislative tracks with different timelines, tax and IT teams should coordinate the two work streams to avoid duplicated system changes and ensure a consistent SAP tax determination and reporting architecture across both reforms.

Expected Next Steps

The bill will be debated in the Congreso de los Diputados and the Senate, where further technical amendments are possible before final publication in the Boletín Oficial del Estado. Businesses should also expect subsequent Spanish legislation transposing the more substantial digital reporting and platform-economy elements of ViDA ahead of the July 2028 and July 2030 EU deadlines.

How Can KGT Support You?

KGT helps multinationals translate legislative change like Spain's ViDA transposition into working SAP configuration. Our SAP-integrated e-invoicing and VAT compliance add-ons manage OSS/IOSS reporting, fiscal representative data, and VAT registration master data, while our SAP Document and Reporting Compliance (DRC) services keep your e-invoicing and digital reporting scenarios aligned as EU and Spanish requirements evolve in parallel through 2027, 2028, and 2030.

Official Sources

This update is provided for general informational purposes only and does not constitute tax advice. It does not take into account the specific facts and circumstances of any taxpayer.

Country update for Spain
16 June 2026
Spain
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