On June 15, 2023, the Spanish State Tax Administration Agency (Agency Estatal de Administracion Tributaria) published further information on the future B2B e-invoicing system. They have been included in the draft royal decree, which details e-invoicing requirements under Law 18/2022, better known as the "Crea y Crece.”
The model adopted in Spain is a decentralized CTC using a public portal and certified providers of private platforms. A publicly available portal for electronic invoicing will also function as an invoice repository.
E-invoicing Implementation Timeline
Launch of electronic invoicing on the previously assumed date, i.e., July 2024. seems impossible under these circumstances. This is because these provisions may enter into force 12 months after publication in the Gazette. Within this period, the obligation will cover large enterprises, while other taxpayers will be covered by it 24 months after publication.
The fact that Spain is still waiting for the consent of the European Commission in this regard does not help in determining the precise date of entry into force of e-invoicing.