PEPPOL IN EUROPE
E-invoicing in Spain
B2G e-invoicing has been mandatory for certain entities in Spain under Law 25/2013 since 2015. Currently, the obligation to send and process e-invoices as part of B2G covers all relationships between suppliers and recipients where the value of transactions exceeds EUR 5,000.
The Spanish Tax Authority is the State Tax Administration Agency. For B2B e-invoicing, which is currently voluntary, the FACeB2B platform has been introduced as a General Entry Point (GEP) to encourage entrepreneurs to use electronic invoicing.
On March 22, 2023, Spain concluded public consultations regarding the planned implementation of B2B e-invoicing. The Spanish government wanted to find out how entrepreneurs, social organizations, public entities, and providers of technological solutions related to the planned implementation of mandatory e-invoices. Based on the draft law Ley Crea y Crece (Creation and Growth of Companies) in Spain, e-invoicing for B2B transactions will soon become mandatory. Giving an exact date of its entry into force is somewhat difficult at this stage, but it seems likely that it will take place in the second half of 2027. This is related to the fact that the B2B regulations will not enter into force until 12 months after publication in the Official State Gazette, and this has not yet taken place.
However, it is known that 12 months after the publication of the final regulations, large taxpayers (turnover over EUR 8 million) will be covered by them, and after another 12 months, they will become applicable to all other taxpayers. Detailed requirements and technical specifications are not yet known, but information on the planned activities has been provided.
The e-invoicing obligation will apply only to domestic B2B transactions, which means that cross-border B2B transactions concluded between parties, one of which is not established or has a permanent establishment in Spain, will be exempt from it. In addition, transactions are documented with simplified invoices and those that do not have to be documented with an invoice (for example, B2C transactions).
Within the first 12 months after the Royal Decree comes into force, companies will need to issue e-invoices with a PDF document, ensuring their legibility for companies for which the obligation to receive e-invoices has not yet entered into force. B2B e-invoicing in Spain follows the post-audit model.
The Spanish Tax Agency has introduced updated web services for submitting and querying invoices in the PREPRODUCTION environment, applicable to both Verifactu and non-Verifactu systems.
As of December 2, 2024, these new services included options for submitting invoices upon request for non-Verifactu systems and querying invoices for Verifactu systems. The updated WSDL (Web Services Description Language), along with the necessary access URLs, can be found on the Developer Portal.
Key updates included in the new web services:
- Introduction of new invoice submission services for non-Verifactu systems
- New invoice query services tailored for Verifactu systems
- Revised WSDL with additional XSDs (XML Schema Definitions) for query functionality
- Updates to Web Services Description and Validation/Error documentation
- Enhanced test client now supporting the new services
