Digitalisation has revolutionised the way companies manage their processes, and electronic invoicing (e-invoicing) has become a powerful tool for modernizing administrative and fiscal management. In Spain, the shift towards mandatory e-invoicing for all companies is at the core of recent reforms aimed at improving transparency, reducing delinquent payments and ensuring tax compliance. This article looks at the current state of e-invoicing, certified billing systems and the relevant regulatory context, including initiatives under the recently approved EU ViDA package (for prior coverage, see the tax alert dated 19 November 2024).
Spain’s "Crea y Crece" Law (Law 18/2022 of 28 September 2024) establishes the mandatory use of e-invoicing for B2B transactions (i.e., transactions between companies and freelancers), reinforcing the value of a standardised system for all commercial transactions, which improves administrative efficiency and enhances transparency in business relationships.
Additionally, a law dating from 2021 (Law 11/2021) introduced a requirement to use certified billing software to prevent the use of dual-use software that allows the manipulation of accounting data. Royal Decree 1007/2023, released on 6 December 2023, sets out the requirements for certified billing systems, ensuring the integrity, accessibility and traceability of accounting records. Verifactu—the public tool created for this purpose—enables the submission of billing records to Spain’s tax authorities at the time they are issued, strengthening fiscal control.
Veri*factu has several key features, such as the inclusion of a QR code and a digital signature on each invoice to ensure authenticity and immutability. This system also enables anomalies to be detected, allows backup restoration and the logging of data export events, thus improving record security and providing a complete history of transactions.
It was originally intended that all businesses and professionals in Spain adopt certified billing systems by 1 July 2025. However, due to delays in the publication of Ministerial Order HAC/1177/2024, which specifies the technical requirements, an amendment has been proposed that would postpone the implementation date to 1 January 2026 for legal entities (corporate income tax taxpayers) and 1 July 2026 for all other taxpayers. Taxpayers that already maintain their record books through the “Immediate Supply of Information” (SII) system would be exempt from certified billing system obligation.
The extension of the deadline aims to prevent an overload of technical queries to the tax authorities and provide more time for software developers and users to adapt to the new requirements.
E-invoicing in Spain is being phased in gradually, with the timing depending on the size of the company. Companies with annual turnover exceeding EUR 8 million will have to comply with the obligation one year after Spain’s regulation for the implementation of e-invoicing is approved (and which is currently being reviewed by the European Commission), while smaller companies and freelancers will have two years.
One of the most formidable challenges for EU member states is the need to obtain a waiver from article 232 of the EU VAT directive (Directive 2006/112/EC), which provides that e-invoicing can be mandatory in an EU member state only if the recipient agrees; in other words, a supplier cannot force e-invoicing on its customer. This obstacle has led to delays in the final approval of Spain’s regulation that will set out the requirements for e-invoicing in the country, as the government awaits a decision from the European Commission.
E-invoicing will not only improve companies' administrative efficiency but will also provide the tax authorities with greater access to transaction data, facilitating the traceability of operations and helping to minimise past due payments. This measure complements other initiatives, such as the SII and the SILICIE projects for special taxes, which will improve transparency and fiscal control of commercial activities in Spain.
The ViDA (VAT in the Digital Age) package that was agreed to by the EU member states on 5 November 2024 aims to adapt VAT management to the digital age by encouraging the use of modern technologies to improve the efficiency and effectiveness of tax collection. This plan aligns with the mandatory use of e-invoicing and other requirements designed to harmonise invoicing processes across the EU—under the agreed package, e-invoicing will be the default standard as from 1 July 2030.
One of the most relevant measures of ViDA is the introduction of an electronic information system that will enable the real-time exchange of invoicing data between companies and the tax authorities. This measure aims to reduce the VAT gap, optimise transaction control and facilitate cooperation between EU member states. In the Spanish context, implementation of Veri*factu and the progress towards e-invoicing are clearly aligned with the ViDA objectives.
Alvaro Gomez-Elvira
BDO in Spain
Background: Obligation to Use E-Invoicing and Billing Software (Veri*factu)
Spain’s "Crea y Crece" Law (Law 18/2022 of 28 September 2024) establishes the mandatory use of e-invoicing for B2B transactions (i.e., transactions between companies and freelancers), reinforcing the value of a standardised system for all commercial transactions, which improves administrative efficiency and enhances transparency in business relationships.Additionally, a law dating from 2021 (Law 11/2021) introduced a requirement to use certified billing software to prevent the use of dual-use software that allows the manipulation of accounting data. Royal Decree 1007/2023, released on 6 December 2023, sets out the requirements for certified billing systems, ensuring the integrity, accessibility and traceability of accounting records. Verifactu—the public tool created for this purpose—enables the submission of billing records to Spain’s tax authorities at the time they are issued, strengthening fiscal control.
Current Status of Billing Systems (Veri*factu)
Veri*factu has several key features, such as the inclusion of a QR code and a digital signature on each invoice to ensure authenticity and immutability. This system also enables anomalies to be detected, allows backup restoration and the logging of data export events, thus improving record security and providing a complete history of transactions.It was originally intended that all businesses and professionals in Spain adopt certified billing systems by 1 July 2025. However, due to delays in the publication of Ministerial Order HAC/1177/2024, which specifies the technical requirements, an amendment has been proposed that would postpone the implementation date to 1 January 2026 for legal entities (corporate income tax taxpayers) and 1 July 2026 for all other taxpayers. Taxpayers that already maintain their record books through the “Immediate Supply of Information” (SII) system would be exempt from certified billing system obligation.
The extension of the deadline aims to prevent an overload of technical queries to the tax authorities and provide more time for software developers and users to adapt to the new requirements.
Current Status of E-Invoicing in Spain
E-invoicing in Spain is being phased in gradually, with the timing depending on the size of the company. Companies with annual turnover exceeding EUR 8 million will have to comply with the obligation one year after Spain’s regulation for the implementation of e-invoicing is approved (and which is currently being reviewed by the European Commission), while smaller companies and freelancers will have two years.One of the most formidable challenges for EU member states is the need to obtain a waiver from article 232 of the EU VAT directive (Directive 2006/112/EC), which provides that e-invoicing can be mandatory in an EU member state only if the recipient agrees; in other words, a supplier cannot force e-invoicing on its customer. This obstacle has led to delays in the final approval of Spain’s regulation that will set out the requirements for e-invoicing in the country, as the government awaits a decision from the European Commission.
E-invoicing will not only improve companies' administrative efficiency but will also provide the tax authorities with greater access to transaction data, facilitating the traceability of operations and helping to minimise past due payments. This measure complements other initiatives, such as the SII and the SILICIE projects for special taxes, which will improve transparency and fiscal control of commercial activities in Spain.
ViDA Package and E-invoicing
The ViDA (VAT in the Digital Age) package that was agreed to by the EU member states on 5 November 2024 aims to adapt VAT management to the digital age by encouraging the use of modern technologies to improve the efficiency and effectiveness of tax collection. This plan aligns with the mandatory use of e-invoicing and other requirements designed to harmonise invoicing processes across the EU—under the agreed package, e-invoicing will be the default standard as from 1 July 2030.One of the most relevant measures of ViDA is the introduction of an electronic information system that will enable the real-time exchange of invoicing data between companies and the tax authorities. This measure aims to reduce the VAT gap, optimise transaction control and facilitate cooperation between EU member states. In the Spanish context, implementation of Veri*factu and the progress towards e-invoicing are clearly aligned with the ViDA objectives.
Alvaro Gomez-Elvira
BDO in Spain