Spain Set to Implement Mandatory B2B E-Invoicing by July 2025
Mandatory electronic invoicing (e-invoicing) for B2B transactions in Spain is expected to come into force in July 2025. This move is part of a broader trend towards digitalization of economic activities, aiming to enhance efficiency and reduce paper usage in business transactions.
Upcoming legislation on B2B e-invoicing in Spain
Spain is set to introduce mandatory e-invoicing for business-to-business (B2B) transactions, with the approval of the relevant legislation expected sometime in May 2024. According to plans, the law will require a minimum of 12 months’ notice before implementation, positioning the earliest possible start date on July 1, 2025, although there is a possibility it will be delayed due to the development of necessary technical specifications and the preparation time required for tax authorities, businesses, and software providers.
The European Commission (EC) recently endorsed Spain’s proposed mandatory e-invoicing legislation, which prioritizes electronic invoices over paper ones, deviating from the EU Directive. The EC's assessment confirmed that the Spanish initiative does not violate EU law, although it did suggest amendments regarding the digital signature and the inclusion of 'seals' for invoices issued by legal entities.
Despite this endorsement, Spain still awaits final approval from the EC to mandate e-invoicing. Complicating matters, the EU’s ViDA Digital Reporting Requirements, which propose eliminating the need for such approvals, are pending acceptance by EU Finance Ministers.
Implementation phases and challenges
Spain is planning a two-phase roll-out. The initial phase will affect large taxpayers (those with a turnover above €8 million), starting potentially in July 2025. All other taxpayers would be required to comply by 2026.
Implementation teams have already flagged potential challenges, indicating that launching before mid-2025 might be problematic due to technical and logistical issues. Furthermore, the EU’s plans for intra-community reporting and e-invoicing under the ViDA Digital Reporting Requirements have been postponed to at least 2030, which may influence Spain’s final decision on the technical requirements and specific launch dates of its own e-invoicing initiative.
Starting July 1, 2025, Spain will also be implementing certified electronic invoice obligations separately, ensuring a comprehensive framework for the digital transformation of financial reporting within the country.
