Spain's electronic invoicing draft royal decree unveiled

The draft royal decree discussed in this article has been subject to numerous updates and changes since its initial unveiling. While the information was accurate at the time of publication, the e-invoicing landscape in Spain has shifted. The earliest new implementation dates for the e-invoicing requirements are unlikely before 2027.

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To stay informed with the most recent developments, including the current status of the regulations and expected implementation timelines, we recommend reading our latest article on Spain's e-invoicing updates here. This will provide you with the most accurate and up-to-date information.

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The draft decree, established under Law 18/2022 of the 28th of September 2022, focuses on key aspects such as the technical requirements for business-to-business (B2B) electronic invoicing. The decree also addresses the interoperability requirements for technological solution providers, as well as the security, control, and standardisation requirements for the devices and IT systems involved in generating e-invoices.

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The Spanish government is currently seeking public consultation on the draft decree until 10 July 2023. Additionally, there is a working group, which includes Unifiedpost Group, where submissions are still being made to the Second Hearing on the Draft Royal Decree, with the aim of reaching a solution that benefits all parties.

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Spain’s chosen e-invoicing model

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Spain aspires to implement the decentralised CTC and exchange model (DCTCE), presumably inspired by the legislation in France and considering the technical requirements of the upcoming VAT in the Digital Age (ViDA) proposal by the European Commission.

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The draft details the use of mandatory e-invoices between Spanish businesses, with an exemption for simplified invoices. The decree establishes the e-invoicing system in Spain, which involves private e-invoicing service providers and a public platform managed by the Spanish Tax Agency (Agencia Tributaria).

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Furthermore, the decree requires businesses to communicate various invoice statuses, such as invoice acceptance, rejection and full payment, including the effective date of payment of the invoice, to both other businesses and the Spanish public platform within four calendar days (excluding weekends and national holidays).

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The businesses themselves can decide on which transmission channel to use: via a private service provider or through the public platform. Businesses that choose to use a private service provider to receive their invoices, have the responsibility to inform their business partners about the e-invoicing entry point.

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On the other hand, service providers were originally required to electronically report transactional data to the public platform in the national format, Facturae, which is currently used for B2G e-invoices. According to the changes proposed in the new Draft Law of 5 March 2025, however, this format has now been changed to UBL for B2B e-invoicing.

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Spain’s e-invoicing technical requirements

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Legal formats

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The Royal Decree defines an electronic invoice as a structured computerised message that adheres to the semantic data model EN 16931 established by the European Committee for Standardisation. The electronic invoice can be expressed in one of the following syntaxes:

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• XML CEFACT
• UBL
• EDIFACT
• Facturae
• Or any other, added additionally by order of the Minister for Economic Affairs and Digital Transformation

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All e-invoices issued through private e-invoicing platforms must be signed with an advanced electronic signature and be assigned a Unique ID - a combination of fiscal identification of the sender, invoice number and series, and invoice date.

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In the first roll-out phase, e-invoices need to be accompanied by a PDF that ensures their legibility for companies and professionals for whom the obligation to receive electronic invoices has not yet come into force.‍

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What to expect from your private e-invoicing service provider?

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When choosing a provider for the upcoming Spanish B2B e-invoicing mandate, make sure they can meet these key requirements:

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• Connection with the public platform: Providers must be able to connect to Spain’s public e-invoicing solution and ensure that transaction data and mandatory statuses are automatically communicated to the authorities.
  
  
• Full interoperability: They should offer free interconnection and seamless interoperability with other platforms in the Spanish system, so you can easily exchange invoices with any customer or supplier.
  
  
• Support for all invoice formats: Your provider should handle all the invoice syntaxes allowed under the new law (including transforming invoices between different formats as needed) and support domestic and cross-border e-invoicing.
  
  
• Security and compliance: The provider’s information security management system should be ISO/IEC 27001 certified (or equivalent) and ensure data governance and confidentiality - even beyond their contractual obligations.
  
  
• Secure transmission protocols: Look for providers using secure protocols that meet AS2 or AS4 specifications for reliable data exchange.
  
  
• Advanced electronic signatures: Providers must be able to handle advanced e-signatures that comply with the eIDAS Regulation (EU 910/2014), ensuring invoice authenticity and integrity.
  
  
• Business continuity and availability: Providers should have a robust business continuity plan and provide around-the-clock support resources to handle high invoice volumes and critical operations.
  
  

• Automated processes: Expect a fully automated process to streamline your invoice management and guarantee compliance at both the national and international level.

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What to expect from the public platform?

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• The public platform will act solely as an invoice repository, storing information on electronic invoices and their copies, as well as information on their payment.
• The public platform originally used Facturae as a syntax, but according to the Draft Law of 5 March 2025, it will now use UBL.
• Invoice content is limited to the UBL format, replacing the previously used Facturae syntax as of the recent draft amendment.
• Submission and receipt of e-invoices via the platform available after authorisation by the Tax Agency.
• Possibility to report the mandatory invoice statuses.

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Expected timelines for mandatory regulations

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The Royal Decree will become effective twelve months after its official publication in the Boletín Oficial del Estado (BOE, the Official State Gazette), with the subsequent implementation phased based on business size as set out in the Draft Decree. The accompanying dates provided here are tentative based on the expected publication timeline, and the detailed phases are as follows:

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• 12 months after the final publication of the Decree (expected 2027): Companies and freelancers with an annual turnover exceeding € 8 million will be required to issue and receive electronic invoices and comply with the mandatory status reporting requirements.
  
  
• 24 months (expected 2028): Companies and freelancers with an annual turnover under € 8 million will be required to issue and receive electronic invoices. For these taxpayers, mandatory status reporting will not be required at this stage.
  
  
• 36 months (expected 2029): Companies and freelancers with an annual turnover under € 8 million will additionally be required to comply with the mandatory status reporting requirements.

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E-invoicing solutions for Spanish businesses

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Ensure compliance, ease of implementation and a future-proofed service that enables 100% automation for years to come, with Unifiedpost Group’s e-invoicing solution, designed to meet the needs of Spanish companies. Using our services effortlessly, create, send and receive electronic invoices in any desired format through any channel.

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Explore an e-invoicing solution suited for your business and ensure compliance with Spain’s upcoming B2B regulations.