Spain Launches Second Public Consultation on “Crea y Crece” E-Invoicing Rules

Spain continues to advance its Crea y Crece e-invoicing mandate with the launch of a second public consultation on the draft Royal Decree, introducing several important regulatory clarifications.

One of the most notable changes is the decision to adopt UBL (Universal Business Language) as the format for the public e-invoicing solution, replacing the earlier Facturae syntax. This move aligns Spain’s approach more closely with the EU’s VAT in the Digital Age (ViDA) framework.

Key Regulatory Updates Under Consultation

• Payment information clarity: Clear rules for credit and debit notes, including standardised methods to calculate payment terms with defined start and end dates.
• VERI*FACTU alignment: Invoices generated through the public platform will be VERI*FACTU compliant.
• “True copy” rules updated: Revised requirements for invoices exchanged via private networks.

Proposed Implementation Timeline

While the final start date is still not confirmed, the mandate will apply no earlier than one year after the ministerial order is approved. The updated proposed timelines are:

• After 1 year:
  Legal entities and sole traders with an annual turnover above EUR 8 million must send and receive e-invoices, including invoice status reporting.
• After 2 years:
  Legal entities and sole traders with an annual turnover below EUR 8 million must comply with the same requirements.

Technical specifications are still under development and will also be subject to public consultation. Businesses are advised to closely monitor upcoming announcements for confirmation of the final implementation dates and technical details.