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.
The Spanish government is currently seeking public consultation on the draft decree until the 10th of July 2023.
Spain’s chosen e-invoicing model
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.
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).
Furthermore, the decree requires businesses to communicate various invoice statuses, such as invoice acceptance, rejection and full payment, to both other businesses and the Spanish public platform within four days.
The businesses themselves can decide on which transmission channel to use: via a private service provider or through the public platform. Businesses who 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.
On the other hand, service providers are required to electronically report transactional data to the public platform in the national format, Facturae, which is currently used for B2G e-invoices.
Spain’s e-invoicing technical requirements
The Royal Decree defines an electronic invoice as a structured computerised message that adheres to the semantic data model EN16931 established by the European Committee for Standardisation. The electronic invoice can be expressed in one of the following syntaxes:
- XML CEFACT
- Or any other, added additionally by order of the Minister for Economic Affairs and Digital Transformation
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.
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.
What to expect from your service provider?
- Interoperability with other service providers and the public platform at no cost
- To operate with advanced electronic signatures
- The ability to exchange electronic invoices in all the permitted syntaxes
- Communication of the transactional data and mandatory statuses to the public platform
- A fully automated process
- Covering domestic and cross-border e-invoices
- National and international tax compliance
What to expect from the public platform?
- Facturae as a syntax used by the public platform
- Invoice content is limited to Facturae syntax
- Submission and receipt of e-invoices via the platform available after authorisation by the Tax Agency
- Possibility to report the mandatory invoices statuses
Expected timelines for mandatory regulations
Issuing and receiving electronic invoices
- Q4 2024 - 12 months after publishing the Decree - For companies and freelancers with an annual turnover of over 8M EUR
- Q4 2025 - 24 months after publishing the Decree - For companies and freelancers with an annual turnover of under 8M EUR
Mandatory reporting of statuses
- Q4 2024 - For companies and freelancers with an annual turnover over 6M EUR
- Q4 2026 - For companies with an annual turnover under 6M EUR
- Q4 2027 - For sole ownership companies or freelancers with an annual turnover under 6M EUR
E-invoicing solutions for Spanish businesses
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.
Our comprehensive suite of inbound (Collect) and outbound (Channel) solutions for large businesses, and our all-in-one solution for smaller businesses (Banqup), is 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.
Explore an e-invoicing solution suited for your business and ensure compliance with Spain’s upcoming B2B regulations.