Spain Releases Further Details on Upcoming B2B E-Invoicing Mandate

The Spanish government has published a new draft Royal Decree that further develops the B2B e-invoicing requirements introduced under Law 18/2022, commonly known as “Crea y Crece”.

This draft provides additional clarity on the technical model, formats, timelines, and obligations that will apply to businesses and service providers once the mandate takes effect.

Spanish E-Invoicing Model

Spain’s e-invoicing framework will consist of:

• Certified service providers, and
• A public electronic invoicing platform, which will also act as a central invoice repository managed by the tax authority.

The chosen approach follows a decentralized CTC-style model, similar to the upcoming French mandate.

Supported Invoice Formats

Certified service providers must support the following syntaxes:

• Facturae
• CII
• UBL
• EDIFACT

In addition, service providers must send a copy of each invoice to the public platform in Facturae format.

Digital Signature Rules

• A digital signature is mandatory when issuing invoices through certified service providers.
• Digital signatures are not required when invoices are issued directly via the public platform.

Mandatory Invoice Responses

Invoice recipients must send status updates to the issuer, including:

• Commercial acceptance or rejection, with date
• Full payment confirmation, with date

Additional optional response types are defined in Article 8 of the draft decree.

Proposed Timelines

• Businesses with an annual turnover above EUR 8 million must issue e-invoices 12 months after publication of the Royal Decree.
• All other businesses must comply 24 months after publication.
• If the recipient is not yet in scope, the issuer must attach a PDF copy to the XML invoice.

For invoice status reporting

• Businesses with a turnover below EUR 6 million must start sending responses 36 months after publication.
• Self-employed professionals below the same threshold must comply 48 months after publication.

Requirements for Certified Service Providers

Article 10 of the draft Royal Decree outlines key requirements, including:

• Support for AS2 or AS4 communication protocols
• Ability to apply advanced electronic signatures under Regulation 910/2014
• Capability to exchange and convert invoices between Facturae, UBL, CII, and EDIFACT formats before signing and delivery
• ISO 27001 certification, among other security and operational requirements

This draft Royal Decree provides important clarity on how Spain plans to operationalize B2B e-invoicing under the Crea y Crece law, while final timelines and technical specifications continue to evolve.