The landscape of Spain’s B2B electronic invoicing regulations is rapidly evolving. The government first announced its intentions to mandate business-to-business (B2B) electronic invoicing in September 2022, but has recently, in March 2025, launched a second public consultation on the Draft Royal Decree under the Crea y Crece law, open until 7 April 2025, bringing significant changes to the initial plans. So what is the latest information you need to know?
In this updated blog, you will find a summary of the key latest updates, a revised B2B e-invoicing rollout plan, and 10 essential facts to help you understand Spain's evolving e-invoicing law.
Latest key updates
Here are the most recent changes to Spain's e-invoicing regulations that are proposed as part of the second public consultation of the Create and Grow Law:
- UBL replaces Facturae: UBL (Universal Business Language) will now be the required format for Spain’s public invoicing system, replacing Facturae.
- Payment term clarifications: Clarifications have been provided regarding payment terms for credit and debit notes, including start and end dates.
- 12-month notice period confirmed: A 12-month notice period has been confirmed, meaning implementation is unlikely before 2027.
On a somewhat related note, and addressing broader invoicing compliance, invoices created on the public platform will also be VERI*FACTU compliant. This requirement does not stem from the 'Create and Grow Law' but rather from the Anti-Fraud Law. (See below for further information about VERI*FACTU)
Create and Grow Law
Once approved, the implementation of the new regulations will be phased as follows:
- 12 months after publishing in the Gazette (expected 2027): Large businesses (turnover > € 8M).
- 24 months after publishing in the Gazette (expected 2028): SMEs and all other taxpayers.
10 essential facts about Spain's B2B e-invoicing law, “Create and Grow”
We have put together the top 10 points to help you understand Spain's law - Ley Crea y Crece (Create and Grow) - and current proposed amendments, from the most recent regulation dates to the finer details of invoice formats and business sanctions. Please keep in mind that the latest proposed changes are based on the current draft and are subject to further change until the regulations are finalised and officially published.
1. Entry into force
From the adoption of the regulation:
- 12 months after publishing in the gazette, expected in 2027: Obligation for companies and professionals with a turnover above € 8 million.
- 24 months after publishing in the gazette, expected in 2028: Obligation for companies and professionals with a turnover below € 8 million.
The turnover period considered 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
What updates to invoice statuses must be reported?
- Mandatory statuses include the commercial acceptance or rejection of the invoice and its date, as well as the full effective payment and its date.
- Businesses must notify these statuses within 4 calendar days from the date of the notification of the status.
- This requirement aims to provide benefits such as reduced late payments, improved invoice tracking, and greater transparency in business relationships.
- By law, the maximum payment period is 60 days.
4. Signature
The rules concerning electronic signatures are as follows:
- The invoice issuer must either sign the invoices, or:
- They may choose to 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 businesses and professionals of 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 in the first wave can keep their current invoice issuing methods until their obligation date, but they may issue electronically voluntarily.
6. Formats
It is vital to understand which electronic invoicing formats will be accepted within the regulations. Notably, with the second public consultation launched in early 2025, there has been a significant change: while currently Facturae is used, the public solution will transition to UBL (Universal Business Language) to align with the European standard EN 16931 and the upcoming VAT in the Digital Age (ViDA) initiative.
- Public solution: UBL (Universal Business Language).
- Private solutions: The billing platforms, solutions, or systems used by electronic invoice issuers will be required to send the true copy to the public electronic invoicing solution in UBL format. Other formats may be used for private exchanges, but UBL is mandatory for communication with the public platform.
7. Public platform
Many governments around the globe utilise a public/government platform within their B2G and B2B regulations.
- Minimal solution for issuing invoices to suppliers and access customer invoices. Explicitly, it will not transmit the invoices, but only make them available for receivers. It will only act as an invoice repository.
- 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)
- E-reporting to the SII will continue to work as before.
- E-invoicing and e-reporting are two separate 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) is envisaged.
10. International invoicing
- There is no specific regulation at the international level, but at the European level, project ViDA (VAT in the Digital Age), which includes provisions for intra-Community e-invoicing and e-reporting requirements, is planned to take effect in July 2030.
- Learn more about ViDA via our blog post.
While these ten points cover the core of the upcoming B2B e-invoicing mandate, it's also crucial to understand two other related regulatory systems impacting invoicing in Spain: VERI*FACTU and TicketBAI.
What is VERI*FACTU?
VERI*FACTU, a Regulation governing the requirements for Billing Computer Systems (RRSIF), is a method for complying with Spanish legislation on computerised billing systems. It guarantees the integrity, conservation, accessibility, legibility, traceability and immutability of billing records.
Most businesses and self-employed persons in Spain who pay income or corporation tax will be required to use compliant invoicing systems for all their invoices, whether full or simplified. This requirement will take effect from 1 January 2026. However, those who already report through the Immediate Supply of Information (SII) system and those with specific exemptions for certain transactions are not required to comply with these new rules.
Invoices created on the public platform will be VERI*FACTU compliant and will include a QR code for validation and communication with the tax authorities.
What is TicketBAI?
TicketBAI, a system introduced by the Basque Country's Foral Tax Authorities, requires businesses to send and certify invoices for all economic activities. Developed in collaboration with the three Foral Treasuries and the Basque Government, TicketBAI establishes specific legal and technical obligations for billing software.
The system aims to control income from economic activities, particularly those involving transactions with final consumers. In order to adhere to TicketBAI regulations, which came into effect in regions such as Bizkaia on 1 January 2024, businesses must use compliant software such as Banqup. TicketBAI ensures the integrity and traceability of billing records by requiring specific data to be submitted to the tax authorities.
How Banqup 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 Banqup, 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.
Introducing Miguel, our Regional Head of Iberia, overseeing Spain and Portugal. With a Masters 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.
