Characteristics of Electronic Invoicing in Spain

In Spain, electronic invoicing is mandatory in the public administration sector. The Law 25/2013 regulates the issuance of invoices in the Facturae format in commercial relationships between the administration and its suppliers since 2015. From 2018, this obligation also extends to subcontractors and contractors working with the public administration, who must electronically send their invoices through the FACe platform when the amount exceeds €5,000.

 

In the B2B sector, the Proyecto de Real Decreto (Draft Royal Decree), developed under Law 18/2022, establishes electronic invoicing as the sole permissible system allowed in commercial transactions between companies. The technical regulation for B2B electronic invoicing in Spain is expected to be approved in 2024, and its implementation will be extended gradually during 2025/2026 depending on companies' invoicing volumes.

Obligation

Obligation

B2G: Electronic invoicing is mandatory in relations with public administrations, as well as in dealings between subcontractors and contractors in the public sector.

B2B: Spain is preparing for the implementation of electronic invoicing between companies and self-employed individuals during 2025 and 2026, following the official publication of the technical regulation of the B2B invoicing system.

Required Administrative Transactions

Required Administrative Transactions

B2G: A digital certificate is required for the mandatory signing of invoices. Alternatively, the "delegated electronic signature" service of a qualified technology provider can be used.

B2B: A digital certificate is necessary for the mandatory signing of invoices between companies (To Be Confirmed - TBC).

Format

Format

B2G: Facturae, this is a structured format (XML) that suppliers and creditors are obliged to generate in their dealings with the public administration.

B2B: The accepted formats for invoicing between companies are: XML CII, UBL, EDIFACT, and Facturae (TBC).

Electronic Signature

Electronic Signature

B2G: Mandatory, an XAdES electronic signature must be applied to invoices addressed to the public administration.

B2B: Mandatory, an advanced electronic signature in accordance with the eIDAS Regulation on electronic identification and trust services must be applied (TBC).

Tax System in Spain

Tax System in Spain

Spain has an extensive electronic tax system, which for its proper functionality, is comprised of various subsystems. Among them, we find:

Archiving

Archive

B2G: Mandatory for the issuer for a legal period of 5 years.

B2B: *To be defined with the official publication of the B2B invoicing technical regulation.
 

Tax Authority

Tax Authority

State Tax Administration Agency (AEAT).

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How Does Electronic Invoicing Work in the Public Sector in Spain?

The following is the process for issuing invoices through the PGEFe (Punto General de Entrada de Facturas Electrónicas/General Entry Point for Electronic Invoices) of public administrations or FACe.
1

Issuance and Validation

Extraction of the data from the supplier's ERP for its transformation into the XML schema - Facturae as defined by the Tax Authority. Various and distinct data validation mechanisms are applied to ensure they contain the necessary information.

2

Digital Signature

The electronic signature mechanisms established by law are applied, which provide integrity and authenticity to the electronic invoice. This involves the use of advanced electronic signatures based on a certificate (XAdES).

3

Sending to PGEFe

Once the invoice has been validated, it is sent to the PGEFe (General Entry Point for Electronic Invoices) that the public entities have enabled, or to FACe for those entities affiliated with the General Entry Point for Electronic Invoices (PGEFe) of the General State Administration.

4

Electronic Archive

Electronic archive of the XML format - Facturae format of the original invoice with high-security conditions and accessibility for the 5 years required by the Spanish legislation.

How Does Electronic Invoicing Between Companies Work in Spain?

The following is the process for issuing electronic invoices in the private sector in accordance with the requirements established in Law 18/2022 on the creation and growth of companies.
1

Issuance and Validation

Extraction of data from the ERP for the generation of technical invoice formats (EDIFACT, Facturae, XML CII, UBL, etc.) and application of data validation mechanisms to ensure there is the minimum information required in each of the syntaxes.

2

Invoice Sending

Once each document has been validated, the invoice recipient is identified for its sending through specific communication channels (private VAN, EDI gateway, https, sftp, x400, OFTP, AS2, AS4...) with traceability records, delivery confirmation, and processing.

3

Electronic Storage

Electronic safekeeping of issued invoices under an eIDAS Electronic Storage service with evidence records and continuous document reassurance.

4

Status Management

Visibility and integration of the different status acknowledgments or ACK (acknowledgment) for each of the invoices issued according to the technical specifications defined in the project.

Frequently Asked Questions about B2B Electronic Invoicing in Spain

The content of the following questions is subject to change with the official publication of the final technical regulation for B2B electronic invoicing in Spain.

No. Electronic invoices only need to be issued to a recipient customer or supplier located in Spain or is operating in Spain under VAT registration.

Yes, those who are self-employed are also obligated to comply with the B2B electronic invoicing regulation.

The publication dates of the Royal Decree will depend on the completion of the initiated ongoing parliamentary process. The expectation is to have the final technical regulation in 2024, suggesting that the implementation start date for the first phase will be in 2025.

From the final publication of the Royal Decree, implementation deadlines for B2B electronic invoicing will be: one year for companies whose annual turnover exceeds €8 million and two years for the rest of the companies (those with sales below €8 million). 

If a supplier is not required to use electronic invoicing in the initial phase (based on the company's invoicing volume), they will continue sending their invoices in a "traditional" way until their company is required to switch to electronic invoicing.

No, invoices issued by a company to a public entity (B2G) or a final consumer (B2C) are outside the scope of this law.

Yes. The SII is a different system, and companies will have to comply with both processes. Therefore, companies that are already using the SII will have to send their electronic invoices to their suppliers and receive them from their customers.

Companies registered in the Basque Country autonomous community must comply with both regulations. They will need to have a certified provider or Guarantee Software for TicketBAI compliance and a solution for the new B2B electronic invoicing system.

The electronic invoicing platforms must have the ability to connect with each other through secure communication protocols defined in the technical regulations. In addition, they must be compatible with established requirements and ensure service security levels, including the authentication and validation of invoices.

The accepted formats are: UBL, CII, EDIFACT, and Facturae.

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