E-invoicing in Spain

E-invoicing is mandatory in Spain for business-to-government (B2G) transactions. Domestic and foreign businesses that issue invoices over €5,000 to Spanish public sector bodies — such as the central government, regional administrations, public agencies, universities, and hospitals — must use the FacturaE format via the Spanish government’s FACe portal (Punto General de Entrada de Facturas Electrónicas). B2G e-invoices must be digitally signed using a qualified electronic signature. Businesses can issue paper invoices to public administrations if they are for less than €5,000 and the public administration recipient allows the issuance of paper invoices.

E-invoicing for business-to-business (B2B) transactions is not yet mandatory in Spain. However, the Spanish government has announced its “Crea y Crece” law. This regulation intends to make it easier to create (crea) and scale (crece) businesses by targeting the issue of delayed payments — one of the main causes of liquidity and profitability problems for Spanish businesses. The Spanish government hopes e-invoicing will address this and intends to mandate e-invoicing for B2B transactions.

A two-phase launch period has been proposed. Businesses with an annual turnover exceeding €8 million must comply with the B2B mandate within one year of its technical requirements being approved, while all other businesses will have two years. Technical requirements and specifications are yet to be approved and are likely to undergo further public consultation. However, because of Spanish law stating businesses must have at least 12 months’ notice from approval, a mandate being implemented from 2027-2028 is likely.

Spain’s options for implementing a B2B e-invoicing model include a direct exchange between buyers and suppliers using structured formats, or transmission through certified e-invoicing platforms (PCEFs). A central government platform may be used to monitor compliance.

Spain takes a softer approach than other countries with noncompliance penalties. Incorrect or late B2G e-invoicing issues could be simply rejected and payments delayed. However, fines for noncompliance could be introduced as Spain’s e-invoicing mandates evolve.