Is Electronic Invoicing Mandatory in Spain?

Electronic invoicing between businesses and professionals in Spain is set to become mandatory in 2024 (for companies with annual turnover exceeding €8 million) and 2025 (for all remaining businesses), pursuant to Law 18/2022 of 28 September on the creation and growth of companies.

Alessandro Scherini, fiscal contable (Conesa Legal)

Written by Alessandro Scherini

Tax and Accounting Adviser

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Initial Implementation Deadline for Large Companies:

Initially, companies with annual turnover exceeding €8 million were given an implementation period of one year from the approval of the technical regulations governing electronic invoicing. These regulations are being developed as part of the draft Royal Decree that supplements the above-mentioned law and sets out the framework for the issuance and accounting registration of electronic invoices.

Publication of the Draft Royal Decree:

On 20 June 2023, the Draft Royal Decree developing Law 18/2022 of 28 September on the creation and growth of companies — specifically regarding electronic invoicing between businesses, self-employed workers and professionals — was published for consultation. A public information and comment period was opened, which closed on 10 July 2023.

Approval and Revised Deadlines:

Following review by the Council of State, the regulation must be approved by the Council of Ministers and published in the Spanish Official Gazette (BOE). In any event, the draft already references a revision to the timeline, indicating that the mandatory requirement will apply from 1 July 2024.

Scope of the New System:

The new business-to-business electronic invoicing system applies only where both supplier and customer are companies or professionals registered in Spain. The tax authorities will develop the regulatory framework governing the issuance of electronic invoices in electronic format, ensuring their validity in both the public and private sectors. International suppliers and customers may continue to issue and receive electronic invoices in the traditional electronic format, and will not be affected by the new electronic invoicing system.

Implementation Deadlines by Business Turnover:

Based on the deadlines set out following the regulatory development of Article 12 of Law 18/2022 of 28 September on the creation and growth of companies, electronic invoicing will be mandatory where the recipient of the transaction is a business operator, professional or company, as follows:

Within 1 year of the approval of the Regulation governing electronic invoicing, for business operators, professionals and companies with a turnover exceeding €8 million.
Within 2 years of the approval of the Regulation governing electronic invoicing, for business operators, professionals and companies with a turnover below €8 million.

Regulatory Development and Draft Royal Decree:

The aforementioned regulatory development is set out in the draft Royal Decree implementing Law 18/2022 of 28 September on the creation and growth of companies, as regards mandatory invoicing between companies, self-employed individuals and professionals. The text of this draft was submitted for public consultation on 20 June 2023.

View the draft Royal Decree on electronic invoicing here

Download the draft Royal Decree establishing the legal framework applicable to electronic invoicing between business operators and professionals and to electronic invoice exchange platforms, and amending the regulation governing invoicing obligations, as approved by Royal Decree 1619/2012 of 30 November.

What is an electronic invoice?

An electronic invoice is a digital representation of a traditional paper invoice. In Spain, it is used to record commercial transactions in electronic form.

How are electronic invoices sent and received in Spain?

The process of sending and receiving electronic invoices in Spain is carried out through an electronic document exchange system. The typical process is described below, including interaction with public authorities:

Sending Electronic Invoices:

Companies, self-employed workers and professionals who are required to issue electronic invoices use software or platforms that comply with the applicable technical and regulatory standards. These systems generate the electronic invoice in the required format.
Once the electronic invoice has been generated, it is sent to the recipient, which may be another company, self-employed worker or professional. The invoice is transmitted via a secure electronic channel — such as email, an exchange platform, or using advanced electronic signature systems — to ensure the integrity and authenticity of the document.

Receiving Electronic Invoices:

When a recipient receives an electronic invoice, it is stored in their corresponding system or platform. The invoice is then validated to confirm that it meets the applicable legal and technical requirements.
Spanish public authorities are also equipped to receive electronic invoices. To submit electronic invoices to a public body, companies must use the systems or platforms designated for that purpose, following the specific procedures established by the relevant authority.
Public authorities process and archive the electronic invoices received in accordance with the applicable legal and regulatory requirements. This contributes to more efficient administrative processing and a reduction in paper use.
It is important to note that electronic invoices must comply with the established standards in order to ensure their validity and acceptance by both public authorities and private recipients.

Who is required to issue electronic invoices?

Companies, self-employed workers and professionals in Spain who carry out commercial transactions are required to issue electronic invoices.

How are electronic invoices issued?

Electronic invoices are issued in electronic format and must meet the technical and regulatory requirements set out by law. Dedicated software systems or platforms designed for electronic invoicing are used for this purpose.

What are the advantages of electronic invoicing?

Electronic invoicing in Spain offers a range of benefits, including reduced paper and postage costs, faster invoicing processes and greater overall efficiency. It also facilitates tax compliance and reduces the risk of errors.

Can foreign companies issue electronic invoices in Spain?

Yes, foreign companies carrying out commercial transactions in Spain may issue electronic invoices. However, they must comply with Spanish requirements and regulations.

What about invoices from international suppliers and customers?

Invoices from international suppliers are not subject to the electronic invoicing obligation in Spain. The same applies to invoices issued to international customers, which may continue to be issued through traditional means.