Recently, the Ministry of Economic Affairs and Digital Transformation published the draft technical regulation that extends the obligation to issue electronic invoices to all companies in Spain, including SMEs and self-employed individuals, initiating a period of public consultation that concluded on July 10, 2023, where companies and service providers could submit their comments and suggestions regarding mandatory electronic invoicing in Spain.

B2B electronic invoicing will be mandatory in Spain

The project is included in the “Crea y Crece” Law approved in September 2022, which establishes electronic invoicing as the only system that can be used in commercial relations between companies and self-employed individuals in Spain. This initiative will ensure greater agility and control over payments, leading to a reduction in commercial delinquency and promoting business growth.

Draft on the technical regulation of B2B electronic invoicing in Spain

The draft by Spanish authorities outlines the technical requirements for the future law on mandatory electronic invoicing in Spain. It focuses on verifying the payment date, deadline and delinquency control, as well as interoperability, security, and technological standardization standards.

Furthermore, it advances the features of the public invoicing platform managed by the Spanish tax agency, which will serve as a central hub for all electronic invoices, regardless of whether they are processed through this platform or by private providers.

Timelines for the implementation of electronic invoicing in Spain

The preliminary draft presented by Spanish authorities could undergo a “public consultation” process until July 10. Until then, affected companies and service providers could suggest improvements and recommendations that may or may not be considered in the final text.

The final regulation will be drafted after analyzing the comments submitted during the public consultation in the form of a “Royal Decree.” This decree will come into effect immediately upon publication, initiating the countdown for project adherence according to the defined implementation deadlines.

If there are no changes from the presented draft, the timelines to consider from the definitive publication of the Royal Decree will be:

  • One year for companies with annual turnover exceeding 8 million euros.
  • Two years for all other companies (those with sales less than 8 million euros).

Obligations for companies and professionals

While awaiting the publication of the final law that will regulate the mandatory electronic invoicing system in Spain, the draft technical regulation establishes, among other requirements, the following obligations:

  • Mandatory issuance, transmission, and receipt of electronic invoices in their commercial relations with other entrepreneurs and professionals.
  • Providing information on invoice statuses.
  • Ensuring free interconnection and interoperability among technological solutions or platforms. This interconnection and interoperability accreditation process will be determined by regulation.
  • Recipients of electronic invoices cannot compel the issuer to use a specific predefined electronic invoicing solution, platform, or service provider.
  • Maintaining access to electronic invoices for 4 years for recipients. When the recipients are no longer clients of the issuing companies, access must be allowed for the following 3 years after contract termination.
  • Facilitating access, viewing, downloading, and printing of electronic invoices for recipients.

Main benefits of using B2B electronic invoicing in Spain

The use of electronic invoicing offers significant advantages in the daily operations of businesses:

  • Digitalization and optimization of business relationships
  • Reduction in time and costs
  • Increased productivity
  • Enhanced security and reliability of electronic transactions
  • Reduction in delinquency in commercial operations
  • Traceability and control of payments between companies and self-employed individuals
  • Reduction in human errors through process automation

From the Process Consulting Department of addwill, we will be glad to collaborate in your adaptation to the new regulations.

You can contact us by phone at +34 934 875 200 or by email at, or leave your inquiry by clicking here.