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Updated - February 15, 2024
Overview
Business-to-government (B2G) electronic invoicing has been mandatory in Spain since 2015. All public authorities are required to have a system in place to receive electronic invoices via FACe, and all their suppliers are required to submit their invoices electronically through there as well (if the total exceeds €5,000.) FACe is the country's central platform and it is mandatory for central government but optional for regional and local governments.
Invoices must be submitted in FacturaE, an XML-based invoice format, and the standard format used in Spain. Suppliers are free to choose any service provider they’d like, given the provider is able to connect to the FACe platform.
B2B E-Invoicing
Unlike B2G transactions, business-to-business e-invoicing is not mandatory in Spain. Despite this, the country has developed a relatively new platform for B2B e-invoicing that’s open to the public and free of charge. FACeB2B, based off FACeB2G, enables the submission of invoices between subcontractors and contractors of Public Sector contracts.
To this date, there is still not an active mandate in place for B2B e-invoicing. However, Spain is actively working on implementing a legal standard between 2024 and 2026 that will require all vendors to use e-invoicing in B2B transactions.
Service providers like SPS Commerce can help companies comply with standards and submit all electronic documents correctly.
The SII
The SII, is the direct electronic reporting and managing system for VAT (Value-Added Tax) in Spain. Companies can declare details of their billing records through the SII and send them electronically to the AEAT (Spanish Tax Administration Agency.)
The system allows for an efficient and automated way to provide instant communication between the Administration and the taxpayer.
Who is required to use SII?
• Large companies with turnover exceeding €6 million
• VAT Groups
• Those registered in the REDEME (Monthly VAT Refund Register)
Timeline and Latest Updates
From 2024: Large B2B VAT taxpayers are required to have electronic insurance and receipts of invoices. Rules are in place regarding e-invoices and their production, including automated invoicing. This includes certified invoicing systems, and, the voluntary submission of invoices to the Agencia Tributaria - Sistemas y Programas Informáticos o Electrónicos (SIF).
From 2025: Due to changes within the Spanish government and technical challenges, the launch of B2B e-invoicing will likely happen in Summer of 2025. This is specific to companies that make over € 8 million in annual-turnover.
July 1st "Veri*factu Regulation": To prevent tax evasion and record alteration, certification requirements for e-invoicing systems and programs will be mandatory for companies and entrepreneurs.
From 2026: B2B e-invoicing will become mandatory for other corporations and self-employed professionals who make under € 8 million in annual turn-over.
Two-Phase Plan for B2B E-Invoicing
Between 2025 and 2026 there will be a two-phase rollout for B2B e-invoicing. In 2025, 12 months after regulatory framework is approved, large companies who pay taxes in Spain will be required to utilize e-invoicing, and all other taxpayers will be required to start in 2026.
According to the Spanish Parliament and the issuance of this law, the country will need to utilize QR codes to help track invoices digitally. This legal requirement will ensure that software developers and retailers are complying with the latest e-invoicing requirements.
Whether B2B or B2G, all companies operating in Spain are subject to a 6-year archiving period for invoices (electronic or not). Archiving outside of Spain is permitted under certain conditions.
Conclusion
The proposal for mandatory e-invoices for all businesses and non-incorporated businesses for B2B transactions aims to improve business efficiency and fight against VAT fraud.
The mandates integration might be delayed, but it will still become an expected requirement in the upcoming years. With the help of SPS Commerce you can prepare your business for the coming regulations.
