Electronic invoice in Spain
A practical guide to Spain’s B2G and upcoming B2B e-invoicing requirements, including timelines, formats, AEAT reporting, platform compliance and implementation.
Overview
Spain runs a two-speed system. B2G e-invoicing has been mandatory since 15 January 2015, built on the national Facturae format and public entry points, principally FACe. The domestic B2B mandate is legally settled — Law 18/2022 Crea y Crece and Royal Decree 238/2026 of 25 March, published on 31 March 2026 — but it is not yet running.
The reason is a single missing document. The mandate only starts counting once a ministerial order with the technical specifications enters into force, and as of today that order is still a draft. This page therefore separates what is legally fixed from what is still a projection — a distinction that matters more in Spain than in almost any other country.
Four formats
Facturae, UBL, UN/CEFACT CII and EDIFACT are all admitted
UBL to the AEAT
the faithful copy sent to the tax authority must be UBL
No clearance
the AEAT receives a copy but does not pre-approve the invoice
Timeline
Two obligations are already live, two are pending, and one depends on a document that has not been published yet.
Already in force
15 January 2015
B2G e-invoicing becomes mandatory
Suppliers in the categories listed in Law 25/2013 must invoice public bodies electronically through a general entry point. Individual authorities may exempt invoices below €5,000.
2022
Law 18/2022 Crea y Crece
The general B2B mandate is written into law, with the technical detail deferred to secondary legislation. Late payment control is one of the stated objectives alongside tax compliance.
31 March 2026
Royal Decree 238/2026 is published
The regulation settles the architecture, the admitted formats, the status reporting duties and the requirements for exchange platforms. It entered into force twenty days later, but its practical application is deferred.
Still pending
Not yet published
The ministerial order with the technical specifications
A draft went to public consultation in April 2026 and closed on 8 May. It proposes entry into force on 1 October 2026, which would start the clock. Until the final text appears in the BOE, that date is a proposal and nothing more.
Order + 12 months
Businesses above €8 million turnover
The mandate applies twelve months after the order enters into force. On the draft's own date that would be October 2027.
Order + 24 months
All other companies and self-employed professionals
Twenty-four months after entry into force — October 2028 on the same assumption. The AEAT must make its public solution available at least two months before the first mandatory date.
1 July 2030
ViDA digital reporting
EU-wide reporting for intra-Community B2B transactions begins. National CTC systems must be aligned with ViDA by 1 January 2035.
Beware of dates presented as settled. October 2027 and October 2028 circulate widely, but both rest on a draft provision that can still change. The only formulation that is legally safe today is “twelve or twenty-four months after the final ministerial order enters into force”.
B2G today
Spain was among the first EU countries to make public-sector e-invoicing compulsory, and that system has been running unchanged in its essentials for over a decade.
FACe
The federal general entry point for electronic invoices. Autonomous communities and municipalities may run their own entry points or connect to FACe; a public directory lists them all.
Facturae 3.2.x
The national XML format, normally carrying a XAdES electronic signature. The current published version is 3.2.2; FACe accepts 3.2, 3.2.1 and 3.2.2.
—In scope, among others: sociedades anónimas and sociedades de responsabilidad limitada, foreign legal entities, permanent establishments and branches of non-residents, temporary business consortia and certain pension, investment and venture capital funds
—An authority may exempt invoices up to €5,000, and certain invoices issued by foreign service providers
—Invoices are normally to be submitted to the administrative register within 30 days of delivery or performance
—For procurement covered by European rules, contracting authorities must be able to accept invoices compliant with EN 16931, with conversion into Facturae handled on the public side
Acceptance by FACe confirms technical and administrative receipt. It does not mean the supply has been accepted as contractually conforming, and it does not automatically approve payment — a distinction worth keeping in mind when a public customer's payment is delayed.
Scope of the B2B mandate
The B2B obligation applies when four conditions hold at the same time. Missing any one of them takes the transaction outside the mandate.
1The supplier is obliged to issue an invoice under Spanish invoicing rules
2The recipient is an entrepreneur or professional, not a consumer
3The recipient has its place of business, a permanent establishment, tax domicile or residence in Spain
4The transaction relates to that Spanish activity or permanent establishment
The point most often missed
A Spanish VAT number on your customer's side is not by itself enough to bring a transaction into scope. The test is whether the supplier is required to issue the invoice under Spanish rules and whether the transaction is attributable to the customer's Spanish establishment.
Cross-border situations
Spanish → SpanishIn scope once the relevant date arrives
Spanish → Spanish PE of a foreign groupIn scope where the transaction is attributable to that PE
Foreign with Spanish PE → Spanish customerNormally in scope where the invoice arises from the Spanish PE's activity
Foreign without PE → Spanish customerNot automatically in scope; the Spanish invoicing obligation has to be established first
Spanish → other EU member stateNormally outside the domestic mandate; the destination country's own mandate may apply
Spanish → outside the EUOutside the domestic mandate; export and customs rules apply separately
Most ordinary simplified invoices — facturas simplificadas, the Spanish equivalent of a till receipt — are excluded. The exception is the qualified simplified invoice that carries the extended set of recipient data.
How the system works
Spain has chosen neither classic clearance nor a pure Peppol four-corner network. Businesses may use the AEAT public solution, one or more compliant private platforms, or a combination of both. What makes the model distinctive is what happens alongside the exchange.
The exchange in one line
Supplier → supplier's platform → customer's platform → customer
and, at the same time, the supplier's platform sends an exact copy of the invoice in UBL to the AEAT public solution.
That extra branch is what makes the model functionally close to a five-corner reporting model, even though Spanish law never uses the term. The difference from Italian- or Polish-style clearance is real and important:
The AEAT does not have to approve the invoice in advance
No tax clearance code is required before the invoice reaches the customer
The absence of a response from the AEAT does not block the commercial exchange
But the tax authority receives a full copy essentially at the moment of issue
The most accurate description is a hybrid decentralised CTC model with a central government repository and no prior clearance. Where a business uses the public solution directly, the model becomes more centralised: the AEAT then acts as transmission point, recipient and repository at once.
Interoperability between platforms
—Every private platform must connect to the AEAT public solution
—Platforms must accept interconnection requests from other platforms and establish the connection within one month
—No separate charge may be made for interconnection or interoperability
—Invoices and their statuses must be transmitted regardless of which platform the counterparty has chosen
Where a recipient has not published a private platform address, the AEAT public solution becomes the default delivery point. Until direct connections are fully established, the public system can also act as a bridge between platforms.
Formats and standards
The new system is built on the EN 16931 semantic model, but Spain admits an unusually broad set of syntaxes — including one that is not XML at all.
UBL / EN 16931Admitted, and mandatory for the copy transmitted to the AEAT public solution
UN/CEFACT CIIAdmitted as an EN 16931 syntax
FacturaeThe national XML format remains admitted
EDIFACT INVOICAdmitted between private platforms, despite not being XML
Peppol BIS BillingUsable in private infrastructure, since it is UBL and EN 16931 compliant
What this means for your provider
A private platform must be able to process and convert every admitted syntax, not just its own preferred one. A provider that handles UBL well but cannot read Facturae or EDIFACT will not meet the Spanish requirements — which is precisely why format conversion sits at the centre of any Spain project.
Signatures and PDF
Invoices exchanged through private platforms must support the required authenticity and integrity mechanisms, including advanced electronic signatures or seals under national rules and eIDAS. The public solution will rely on its own authentication and NIF verification.
A PDF is not a substitute for the structured invoice in B2G, and will not be one in B2B once the mandate applies. There is one transitional carve-out: during the first twelve months of their obligation, large companies must accompany the structured invoice with a readable PDF copy unless the recipient has expressly agreed in advance to receive only the structured file. That copy is a courtesy, it is not sent to the AEAT, and it does not replace anything.
Statuses, SII and VERI*FACTU
Spain now has three distinct reporting regimes with different legal purposes. Confusing them is the most common source of misunderstanding, so it is worth being precise about what each one does.
B2B e-invoicing
Delivers the legal invoice to the customer and a faithful copy to the AEAT at the moment of issue.
SII
Feeds VAT ledger records to the AEAT. It never delivers the legal invoice to the buyer.
VERI*FACTU / RRSIF
Governs how your invoicing software behaves: immutable records, chained hashes, event logs, QR codes.
Invoice statuses under the B2B mandate
The recipient does not merely receive the invoice — it must report back on it, and those statuses reach the AEAT regardless of which channel was used for the exchange:
—Acceptance or rejection of the invoice
—Full payment, together with the payment date
—Optionally, partial payment and further additional statuses
—The core statuses are due within four calendar days, excluding Saturdays, Sundays and national public holidays
This is where the Crea y Crece objective becomes visible: the payment data feeds the monitoring of payment terms between businesses, not only VAT control.
SII
Suministro Inmediato de Información applies to large companies, VAT groups and members of the monthly refund register, with a general four-day transmission deadline. SII and the B2B mandate will coexist — neither replaces the other, though the legislation anticipates coordination to avoid unnecessary duplication.
VERI*FACTU
The invoicing software rules under Royal Decree 1007/2023 follow their own calendar, deferred by Royal Decree-Law 15/2025:
1 January 2027Corporate income tax payers
1 July 2027Other affected businesses and self-employed professionals
In VERI*FACTU mode the billing records are transmitted to the AEAT automatically as they are created. In the alternative non-VERI*FACTU mode the software must generate and securely retain immutable records, but need not send each one at the moment of creation. Either way, this is a requirement about software, not a substitute for the B2B e-invoice.
Requirements for platforms
A frequent question from foreign businesses: is Peppol certification enough to operate in Spain? It is not. Peppol certification covers transport and format; participation in the Spanish mandatory system requires a provider to meet the national requirements for a plataforma privada de intercambio de facturas electrónicas as well.
What Royal Decree 238/2026 requires of a platform
—Connection to the AEAT public solution
—ISO/IEC 27001 certification or an equivalent standard
—Support for AS2 or AS4 transport
—Support for advanced electronic signatures or electronic seals
—Processing and conversion of all admitted formats
—Business continuity, service availability and support
—Data confidentiality, security and governance
—Free interconnection and interoperability with other compliant platforms
No Spanish company required
The published requirements do not oblige a provider to be a Spanish legal entity, to have Spanish owners, to maintain an office or staff in Spain, or to appoint a Spanish fiscal representative merely to offer a platform. An EU provider can in principle serve Spanish customers, provided it meets the substantive requirements and completes the national onboarding.
The right term is national compliance and technical onboarding into the AEAT B2B system — not a licence comparable to the Slovak digitálny poštár, and not a Spanish Peppol accreditation. The detailed identification, authentication and representation procedures are precisely what the pending ministerial order has to define, which is why no provider can honestly claim today to have completed a fully specified Spanish onboarding.
Peppol's role and the EAS code
Peppol is not the mandatory national channel in Spain. It may be used by a private platform as a transport network and format, but Spanish law does not require domestic invoices to travel over Peppol. There is also no separate Spanish Peppol Authority in the published OpenPeppol list, which means Peppol operators in Spain work under general OpenPeppol rules rather than a Spain-specific requirement set.
For Spanish tax identifiers, Peppol uses EAS 9920, scheme name ES:VAT, with the AEAT as issuing agency, built on the Spanish NIF. This applies when Peppol transport is used; the national system will operate its own directory and endpoint mechanism.
Archiving
Spain has no single retention figure, which trips up more companies than it should. Three different periods can apply to the same invoice, and the longest one governs.
4 yearsThe general tax limitation period under the General Tax Law, during which the tax authority may review and the taxpayer must be able to produce documentation
6 yearsThe Commercial Code requirement for books, correspondence and supporting accounting records, counted from the last entry
LongerFor capital goods subject to VAT adjustment periods, and wherever a longer sector-specific rule applies
The structured file is the original. A PDF rendering of an electronic invoice does not replace it
Authenticity of origin, integrity of content and legibility must be preserved throughout — including any electronic signature attached to a Facturae invoice
Invoices must remain accessible and readable, and be producible on request during an audit
The copy held by the AEAT is not your archive. Spain's public solution stores what it receives for the authority's own purposes; the obligation to retain a complete, readable and verifiable set of invoices stays with the business, whether it keeps them in-house or with a provider.
Penalties
Royal Decree 238/2026 does not introduce a dedicated penalty table for B2B e-invoicing. The general invoicing provisions of the Spanish General Tax Law apply instead, which means the amounts are proportional to the transactions concerned rather than fixed per infringement.
1%of the value of the transactions — for breaching requirements on issuing, transmitting, correcting or retaining invoices
2%of the value of the transactions — for failing to issue or failing to retain an invoice
€300per transaction where the amount cannot be determined
75%of the transaction value — for false or falsified invoices
+100%increase on the calculated penalty in cases of substantial breach of invoicing obligations
Separate regimes, separate penalties
SIILate transmission is generally penalised at 0.5% of the invoice amount, with a quarterly minimum of €300 and a maximum of €6,000
RRSIF€150,000 per financial year and per non-compliant system type for a producer or seller; €1,000 per system lacking the required certification; €50,000 per financial year for a user holding a non-compliant system
B2C sector dutiesFailure to supply a consumer with an electronic invoice where required can lead to a warning or a fine of up to €10,000
Percentage-based penalties behave very differently from the flat fines used in Belgium or Slovakia. A systematic failure — say, an ERP that never sends the copy to the AEAT — is measured against turnover, so the exposure grows with the business rather than with the number of incidents.
How we help
Spain asks more of a service provider than most markets: several formats, two transport protocols, signatures, status handling and a parallel copy to the tax authority. As a certified Peppol Access Point we cover the European side of that today and are preparing for the Spanish national onboarding once the ministerial order defines it:
Peppol BIS Billing 3.0 (UBL 2.1) and UN/CEFACT CII
Facturae 3.2.x for invoicing Spanish public bodies
Conversion between the nationally admitted formats, including EDIFACT INVOIC
Validation against EN 16931 before dispatch
Spanish NIF handling and Peppol EAS 9920 addressing
Integration via API, SFTP and CSV, with ERP and IDoc source data
Traceable status and error feedback for every document
One connection covering Spain and the rest of Europe as national mandates arrive
Frequently asked questions
When exactly does B2B e-invoicing become mandatory?
There is no legally fixed calendar date yet. The mandate applies twelve months after the final ministerial order enters into force for businesses above €8 million turnover, and twenty-four months after for everyone else. The draft order proposes entry into force on 1 October 2026, which would give October 2027 and October 2028 — but the order has not been published in the BOE, so treat those as projections rather than commitments.
Is Peppol certification enough to comply in Spain?
No. Peppol covers transport and the Peppol BIS format, but a platform operating in the Spanish B2B system must additionally meet the national requirements: connection to the AEAT public solution, ISO/IEC 27001 or equivalent, AS2 or AS4, advanced signatures or seals, conversion of all admitted formats, business continuity and free interconnection with other platforms. Peppol may be part of the answer; it is not the whole answer.
Does a Spanish VAT number put my transactions in scope?
Not on its own. The mandate requires that the supplier is obliged to issue the invoice under Spanish invoicing rules and that the transaction relates to the customer's Spanish establishment, permanent establishment, tax domicile or residence. A foreign supplier without a Spanish permanent establishment should not assume it is in scope simply because the buyer holds a Spanish VAT identifier.
How does this differ from SII and VERI*FACTU?
Three separate regimes with three separate purposes. The B2B mandate delivers the legal invoice to your customer and a copy to the AEAT. SII reports VAT ledger records and never delivers an invoice to a buyer. VERI*FACTU and the wider RRSIF rules govern how your invoicing software creates and secures its records, with deadlines of 1 January 2027 for corporate income tax payers and 1 July 2027 for others. None of the three replaces either of the other two.
Do I still have to send a PDF alongside the structured invoice?
Only in one transitional case: during the first twelve months of the obligation for the large-company group, the structured invoice must be accompanied by a readable PDF unless the recipient has expressly agreed in advance to receive only the structured file. That PDF is not sent to the AEAT and never counts as the invoice itself. Outside that window, and in B2C or transactions outside the mandate, a PDF may still serve as an electronic invoice where the recipient consents and authenticity, integrity and legibility are ensured.
Is there a general B2C e-invoicing obligation?
No general obligation to issue structured XML to consumers exists. Sector duties under Law 56/2007 do apply — for electronic communications, financial services, water, gas and electricity, travel agencies, passenger transport and retail — requiring providers to give consumers who request or consent to them an electronic invoice. Consumers must be able to access, read, download, copy and print the invoice free of charge, and to withdraw consent simply and at no cost. Access must survive the end of the contract.
Will an e-invoice be the only basis for deducting VAT?
Not quite. Spanish VAT law requires a proper supporting document, normally the original compliant invoice, though certain other documents such as customs documents are also recognised. Once the mandate applies to a transaction, the structured e-invoice becomes the legally required form, and a PDF or paper document will not meet it. A defective document usually has to be corrected or replaced rather than causing the right to deduct to be lost outright — but the deduction can be delayed until a correct invoice exists.
What about the Basque Country and Navarre?
The foral jurisdictions of País Vasco and Navarra have their own tax administrations, so implementation there requires coordination between the AEAT and the relevant Hacienda Foral. If your Spanish operations sit in those territories, this is worth clarifying early — it is one of the areas where the pending ministerial order and subsequent regional decisions still have to fill in detail.
Summary
Spain's B2B mandate is decided in substance and open in timing. Royal Decree 238/2026 has settled the architecture: a hybrid decentralised model in which invoices travel between private platforms or through the AEAT public solution, while a faithful UBL copy reaches the tax authority at the moment of issue. There is no prior clearance, but there is full visibility.
What remains open is the ministerial order that starts the twelve- and twenty-four-month clocks and defines how platforms actually connect. Until it appears in the BOE, every calendar date in circulation is a projection — including the widely quoted October 2027 and October 2028.
The practical advice is not to wait for the order before preparing. Structured invoice data, clean master data, a Spanish NIF handled correctly and an ERP that can emit EN 16931 are all needed whichever date arrives — and a business already exchanging over Peppol has done a substantial part of the work.
Resources
AEAT – mandatory electronic invoicing
The tax authority's own note on Royal Decree 238/2026 and the public solution
Royal Decree 238/2026 in the BOE
The full legal text of the B2B e-invoicing regulation
facturae.gob.es
The official Facturae format site, with schemas, versions and signature policies
FACe – the general entry point
Submitting invoices to Spanish public bodies, with a directory of all entry points
AEAT – invoicing software and VERI*FACTU
Requirements for billing systems under the RRSIF, with the 2027 deadlines
European Commission – eInvoicing in Spain
Country factsheet covering the legal basis, operating model and scope
Peppol Directory
Check whether a business partner is reachable on the network
