E-Invoicing in Spain

Mandatory Electronic Invoicing in Spain

Simplify your transition to mandatory reporting in Spain by understanding how it fits into the broader digital tax shift across 70+ nations.

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Who is obliged to use e-invoicing in Spain?

B2G e-invoicing has been mandatory in Spain for contracts above EUR 5,000 since 2015.

On March 24, 2026, Spain’s Council of Ministers adopted the Royal Decree implementing electronic invoicing for domestic B2B transactions between companies and professionals. The e-invoicing obligation will apply only to domestic B2B transactions, meaning that cross-border B2B transactions in which one party does not have a permanent establishment in Spain will be exempt. The exemption will also apply to transactions documented with simplified invoices (with the explicit exception of “qualified” simplified invoices) and those that do not have to be documented with an invoice (such as B2C transactions).

B2B E-Invoicing
Implementation Timeline

The B2B mandate will be rolled out in two phases:

  • October 2027: For large taxpayers (turnover above €8 million) – 12 months after Ministerial Order
  • October 2028: All other taxpayers – 24 months after Ministerial Order

VeriFactu, Spain-certified electronic invoice software, will be mandatory from January 1, 2027, for corporate taxpayers that are not subject to the SII Reporting mandate, and from July 1, 2027, for all remaining taxpayers, including entrepreneurs and self-employed professionals.

Within the first 12 months after their e-invoicing obligation takes effect, companies will be required 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, unless the recipient explicitly agrees to receive the structured format alone.

E-invoicing process description

E-invoicing system description

The Spanish e-invoicing system will adopt a hybrid architecture, combining private e-invoicing platforms with a public solution from the Spanish tax authorities, ensuring full interoperability. It will be composed of two channels:

  • Platforms of private providers of electronic invoice exchange systems. Companies using this solution will have to make their e-invoicing point public in all communications with other companies. If they don't do it, the public e-invoicing solution will be considered their entry point by default.
  • A free public solution operated by AEAT.

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E-invoicing process description

Spain requires the cooperation of suppliers of e-invoicing solutions in the interoperability model. They will be required to accept requests to connect to any other platform within one month of receiving a request to do so from their customers, providing technical specifications and a test environment free of charge.

Recipients of e-invoices will be obliged to report the status of invoices to the public solution (SPFE) operated by AEAT within 4 days (excluding weekends and national holidays). In particular, the mandatory statuses will refer to the commercial acceptance or rejection of the invoice (including its date), the payment due date, and the full effective payment date. The public solution will provide the necessary mechanism to handle these communications in the mandatory UBL format.

On this basis, and on the basis of data sent to the publicly available portal, STAA will obtain statistical information on invoice payments that will facilitate monitoring of compliance with the provisions on payment deadlines, as described in ACT 3/2004.

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What is the required format of an e-invoice?

For B2G relations, the Facturae format is used. This is the XML-based national standard (used in association with an eSignature following the XAdES standard).

The format of B2B e-invoices in Spain must comply with the EN 16931 standard. The following will be accepted:

  • CII Industry-wide CEFACT/ONU Invoice XML message as specified in XML Schemas 16B (SCRD- CII)
  • UBL Invoice and Credit note messages in accordance with ISO/IEC 19845:2015
  • EDIFACT invoice messages compliant with ISO 9735
  • Facturae messages (version for invoicing between businesses and professionals), valid at all times

Archiving requirements for e‑Invoicing in Spain

Required storage period is 6 years.

How integrity and authenticity may be ensured?

E-invoices have to be signed by the issuer with an advanced electronic signature. In addition, all e-invoices will have to be identified with a unique QR code, which will include information about the issuer's tax identification number, invoice number, invoice date, and series.

 

How can we help?

Comarch is connected to the B2G FACe platform and to some local platforms (for example, OSAKIDETZA in the Basque Country). Comarch plans to provide full coverage in relation to the requirements of the upcoming B2B mandate.

Why is Comarch the best choice?

We have 20+ years of experience in carrying out various EDI, e-invoicing, and other document exchange projects around the world. In those years, we have successfully connected more than 130,000 entities from over 60 countries.

  • 1. Legal compliance

    Full compliance with the latest data exchange regulations and modern data transfer standards

  • 2. Digitization

    Applying new technologies and IT solutions in order to streamline workflows and automate activities and procedures

  • 3. Individual approach

    Tailor-made solutions based on processes specific to each company – own road map and a suitable pace of changes

  • 4.Security

    Highest level of security for all sensitive and important company data

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