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Compliance and Regulations

10 essential facts on Spain's B2B electronic invoicing law

January 2, 2024

The movement of Spain’s B2B electronic invoicing regulations is accelerating at a fast pace. The government first announced its intentions to mandate business-to-business (B2B) electronic invoicing in September 2022. Just like many mandates around the globe, what the government first announced is now different to the most recent developments. So what is the latest information you need to know?

We have put together the top 10 points to help you understand Spain's law - Ley Crea y Crece (Create and Grow) - current amendments. From the most recent regulation dates, to the finer details of invoice formats and business sanctions. Please note, the latest amendments are still subject to change pending regulation adoption.

1. Entry into force

From the adoption of the regulation:

  • After 12 months, obligation for companies and professionals with turnover above €8 million. Expected in Q2 2025.
  • After 24 months, obligation for companies and professionals with turnover below 8 million euros. Expected in Q2 2026.

The turnover period to be taken into account will be that of the year prior to the entry into force of the obligation.

2. Scope of the law

Who will the law affect and which businesses are in scope:

  • Domestic.
  • B2B, private companies and professionals.
  • Does not affect FACe (B2G).
  • Public companies and UTEs (Unión Transitoria de Empresas) are subject to the law in the same way as private companies.

3. Communication of mandatory invoice statuses

  • Invoice acceptance.
  • Invoice fully paid.
  • According to our understanding there will be some flexibility, as sometimes payment is arranged, but the bank may take ‘x’ days to process the payment.
  • By law, the maximum payment period is 60 days.

4. Signature

The rules concerning electronic signatures.

  • The invoice issuer must sign the invoices or
  • delegate the certificate to their e-invoicing service provider

5. PDF

PDF invoices can fall into various categories, depending on a country’s invoice acceptance factors. Take a look at how the Spanish government will deal with PDF invoices within its B2B regulations.

  • Invoices in PDF format will continue to be accepted until the law becomes mandatory for business and professionals in all sizes.
  • Companies falling in the first wave of the obligation must issue invoices in electronic and in PDF format. They should be capable of receiving invoices in both formats.
  • Companies not part of the first wave will be able to keep the invoice issuing methods they had established with their customers until the date of them falling in the obligation. On a voluntary basis, they may issue in electronic format.

6. Formats

It is vital to understand which electronic invoicing formats will be accepted within the regulations.

  • Public solution: Facturae.
  • Private solutions: Facturae, CII, Edifact and UBL.

7. Public platform

Many governments around the globe utilise a public/government platform within their B2G and B2B regulations.

  • Minimal solution that will allow the issuing of invoices to suppliers and access to customers. Explicitly, it will not transmit the invoice, but only make them available for the receivers to obtain them themselves.
  • A copy of the invoice must be sent to the public platform and the invoice statuses: acceptance and effective payment must be communicated.

8. SII (Suministro Inmediato de Información)

  • The e-reporting to the SII will continue to work as before.
  • E-invoicing and e-reporting are two different processes, running in parallel.

9. Sanctions and control

  • No penalties regime is foreseen for the time being.
  • The State Observatory on Private Delinquency (Observatorio Estatal de la Morosidad Privada) will be responsible for monitoring the evolution of payment data and promoting good practices.
  • The publication of an annual list of non-compliant and late-paying companies (legal entities that fail to pay more than 5% of their invoices on time and whose total amount of unpaid invoices exceeds 600,000 euros) is envisaged.

10. International invoicing

  • There is no regulation at international level, although there is already a project at European level (ViDA - VAT in the Digital Age) planned for 2030+.
  • Learn more about ViDA via our blog post.

How Unifiedpost Group can help

When choosing an electronic invoicing provider to help you navigate the various regulations and to help you become compliant, it can be difficult to understand what your business may need.

With Unifiedpost Group, we guide you through all the changes and we help future-proof your systems so that any regulation changes become our issue and not yours.

We already comply with the regulations in over 60 countries around the world. We tailor our products, and therefore your solution, so that it meets national and international regulations.

How else can we help you and other Spanish businesses?

  • We create value-added fields to the formats, specific to a sector or type of invoice: order/reference number, cost centers, etc.
  • We communicate mandatory statuses to the public platform, with the possibility of including additional statuses between private operators.
  • We provide additional statuses to the mandatory ones, for example: partial payments.
  • We automate the sending and reception of your invoices and invoice statuses.
  • We filter data for uploading and accounting in your ERP or financial systems.
  • We enable digital payments and reconciliations, making it even easier for your business to get paid more accurately and on time.
  • We provide receipt and data capture (OCR) for PDF invoices.
  • We supply advanced signature and electronic archiving.
  • We ensure your local and international compliance.

Start on your journey towards compliant electronic invoicing by discussing your business needs with a member of our Spanish team.

Miguel Mendes Zegre
Country Manager Spain & Portugal

Introducing Miguel, our Regional Head of Iberia, overseeing Spain and Portugal. With a Master's in Computer Science and years of experience in e-invoicing and EDI solutions, Miguel is a seasoned expert in digital transformation. Notable achievements include serving on the board of EESPA (now GENA) and spearheading the launch of e-invoice companies in Latin America.

Connect with Miguel on LinkedIn
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