Spain e-Invoicing Compliance Updates

Invoicing in Spain Highlights

Spain's B2B e-invoicing mandate is now legally in force: Royal Decree 238/2026, implementing the Crea y Crece Law, became mandatory on April 20, 2026, and rolls out in two phases — mandatory structured e-invoicing for businesses with annual turnover over €8 million from October 1, 2027, extending to all remaining businesses, SMEs, and self-employed professionals from October 1, 2028. The standard VAT rate (IVA) is 21%, with a reduced rate of 10% and a super-reduced rate of 4%, administered by the State Tax Agency (AEAT). E-invoices must use a structured format (Facturae, UBL, CII, or EDIFACT) aligned with EN 16931, and a parallel software-integrity regime, Verifactu, becomes mandatory for corporate taxpayers from January 1, 2027.

Requirements Snapshot

Tax Overview

Tax Type: VAT / IVA (Impuesto sobre el Valor Añadido)
Tax Authority: State Tax Agency (AEAT — Agencia Estatal de Administración Tributaria)
Current tax rates: Standard rate: 21%, Reduced rate: 10%, Super-reduced rate: 4%
Currency: Euro (EUR)

Archival Overview

Legal archiving period: 4 years for tax purposes; 6 years under the Commercial Code for business records; 5 years for gold-related transactions; AEAT must be notified if invoices are archived abroad
Archive Location: Storage abroad allowed with notice to AEAT

e-Signature Overview

e-Signature required: Not required for B2B; required for B2G

Business-to-Business (B2B)

Model: Hybrid model. Businesses may exchange e-invoices via accredited private platforms, the Public Electronic Invoicing Solution (SPFE), or both — but if a private platform is used, it must simultaneously submit a faithful copy of the invoice to the SPFE. This sits alongside Verifactu, a separate billing-software certification regime, and the existing SII (Suministro Inmediato de Información) near-real-time reporting obligation (invoice data submitted to AEAT within 4 days) that already applies to large taxpayers
e-invoicing obligations: Mandatory for businesses with turnover over €8 million from October 1, 2027; mandatory for all remaining businesses, SMEs, micro-enterprises, and self-employed professionals from October 1, 2028. PDF and Excel invoices will no longer be considered valid e-invoices once the mandate applies
B2B Invoicing Government Platform: Public Electronic Invoicing Solution (SPFE) — a government-run option, but not the only route; the Ministerial Order regulating the SPFE enters into force October 1, 2026
Invoice issuance requirements: EN 16931-aligned structured invoice (Facturae, UBL, CII, or EDIFACT), issued via an accredited private platform or the SPFE, with a copy always reaching the SPFE
Invoice reception requirements: Businesses in scope must be able to receive and process structured e-invoices via their chosen platform or the SPFE from their applicable go-live date

Business-to-Government (B2G)

e-invoicing obligations: Mandatory since 2015 (Law 25/2013) for invoices to public administrations exceeding €5,000
B2G Invoicing Government Platform: FACe (Punto General de Entrada de Facturas Electrónicas) — the common entry point for all Spanish public bodies
Invoice issuance requirements: Facturae-compliant, digitally signed with XAdES (XML Advanced Electronic Signature) using a qualified digital certificate
Invoice reception requirements: Facturae-compliant via FACe, validated and routed using DIR3 codes
B2G Invoice Formats: Facturae (XAdES-signed XML)

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