Electronic invoicing will cease to be a voluntary option and become a legal requirement in Spain in the coming months. If you have a company or are self-employed, it is essential that you are aware of the implementation deadlines, technical requirements and risks of not adapting in time.
This article provides an up-to-date guide on the gradual implementation of electronic invoicing, which companies are required to use it, the regulations that govern it, and how you can prepare your business to comply with the law without any problems.
What is electronic invoicing?
An electronic invoice is a digital document that replaces the paper invoice and must meet the same legal requirements:
- It must include all mandatory information (issuer, recipient, description, taxable amount, VAT, total, etc.).
- It must guarantee the authenticity of its origin, the integrity of its content and its legibility.
- It must be kept for the legal period (four years according to tax regulations).
According to Law 56/2007 on Measures to Promote the Information Society and the Create and Grow Law (Law 18/2022, of 28 September), electronic invoicing is a tool for modernising relations between companies, reducing late payments and streamlining accounting procedures.
Applicable regulations and implementation schedule
The regulatory change that makes electronic invoicing mandatory for all companies and self-employed persons is contained in the Create and Grow Law, which was published in the Official State Gazette on 29 September 2022.
Article 12 of this law establishes the obligation to issue and send electronic invoices in transactions between businesses and professionals.
The obligation will be implemented in stages:
- Companies and self-employed professionals with an annual turnover of more than £8 million: maximum period of 1 year from the publication of the implementing regulations.
- Other companies and self-employed professionals: maximum period of 2 years from the publication of the regulations.
The regulations implementing this law are currently being processed, so the final deadline has not yet begun. According to official information from the Ministry of Economic Affairs and Digital Transformation, it is expected to be approved in 2025.
Therefore, although the obligation has not yet come into force, it is important that your company prepares now, as the transition will involve technical, organisational and training changes.
Official sources:
- BOE Create and Grow Law: https://www.boe.es/buscar/doc.php?id=BOE-A-2022-15755
- Ministry Electronic Invoicing Portal: https://administracionelectronica.gob.es/pae_Home/dms/pae_Home/documentos/ae_documentos/Facturae.pdf
- AEAT Tax Information for Companies: https://www.agenciatributaria.es
Who is required to issue electronic invoices?
Once the regulation comes into force, the following will be required to use electronic invoicing:
- All companies, SMEs and self-employed persons who carry out transactions with other businesses or professionals in Spain, regardless of their size.
- They will also be required to keep electronic invoices for the legal period and make them available to the Tax Agency upon request.
The rule does not apply to transactions with end consumers (individuals), unless both parties voluntarily agree to electronic invoicing.
Technical requirements for electronic invoices
To comply with current legislation, electronic invoices must:
- Be generated in a structured format that allows them to be read automatically (e.g. Facturae, the most widely used XML format in Spain).
- Include an advanced electronic signature that guarantees authenticity and integrity.
- Allow them to be sent and received by secure electronic means.
- Contain the minimum mandatory data defined by tax regulations.
In the case of transactions with the public sector, the use of the Facturae format has been mandatory since 2015.
Advantages of implementing electronic invoicing as soon as possible
Although many business owners see electronic invoicing as an obligation, the truth is that it also offers clear advantages:
- Cost savings: reduces the use of paper, printing, postage and physical storage.
- Greater control: facilitates the automation of accounting processes and invoice reconciliation.
- Fewer errors: as they are generated digitally, there are fewer errors in data or amounts.
- Faster payments: helps to reduce late payments by providing reliable proof of the date of issue and receipt.
- Tax compliance: improves the traceability of transactions and tax control.
In short, proactively adopting electronic invoicing means modernising the management of your business.
What are the risks of not adapting in time?
If your company or professional activity does not comply with the obligation to issue electronic invoices on time, you are exposed to:
- Financial penalties provided for by the General Tax Law.
- Inability to deduct expenses if the invoice does not meet the requirements.
- Delays in payments if they are not accepted by customers.
- Reputational damage with suppliers or business partners.
That is why it is advisable to plan the change in advance and not wait for the final publication of the regulations to start preparations.
Steps to prepare your company
To implement electronic invoicing smoothly, we recommend that you follow these steps:
- Audit your current invoicing system: identify which programmes you use, which formats you generate and how you manage digital signatures.
- Select a software solution that is compatible with Facturae and electronic signatures: there are many options on the market, some free and others with professional support.
- Inform and train your team: all staff involved must know how to issue, send and store electronic invoices.
- Prepare communication with your customers and suppliers: give them plenty of notice so they know you will be invoicing electronically.
- Define a storage and access protocol: establish how you will store invoices and what security measures you will apply.
If you are unsure how to get started, seeking specialist tax and accounting advice from Gutiérrez Pujadas & Partners will enable you to implement the system with complete security and legal certainty.
How can Gutiérrez Pujadas & Partners help you implement electronic invoicing?
At Gutiérrez Pujadas & Partners, we support small businesses and self-employed professionals throughout the entire process:
- Advice on applicable regulations and implementation deadlines.
- Selection and integration of the electronic invoicing tool.
- Digital signature configuration and technical compliance.
- Personalised training for your team.
- Support in the management and storage of electronic invoices.
Getting ahead of the legal obligation will not only avoid penalties, but will also allow you to professionalise your accounting management and optimise resources.
Mandatory electronic invoicing will soon be a reality for all companies and self-employed professionals in Spain. The sooner you prepare, the fewer risks and costs you will have.
If you need personalised guidance, the team at Gutiérrez Pujadas & Partners is ready to help you take the plunge with confidence and peace of mind.
Contact us today and modernise your invoicing system before it’s too late.