Country Situation
In Spain, B2G e-invoicing has been mandatory for suppliers to public administrations since January 2015, under Law 25/2013. Invoices must be issued in the structured Facturae XML format (version 3.2 or higher) with a digital signature, ensuring compliance with EN 16931 standards. Each invoice must also include a DIR3 code, which identifies the relevant administrative body.
There is a central platform that covers almost all potential customers. That being said, some additional platforms exist, particularly in the basque country, which are not connected to FACE. These are expected to remain in place during the implementation of B2B e-invoicing.ae XML format (version 3.2 or higher) with a digital signature, ensuring compliance with EN 16931 standards. Each invoice must include a DIR3 code.
There is a main Central Platform that covers almost all the potential customers, but there are some other platforms, specially in the basque country that are not covered by FACE. It is expected to be kept during the B2B implementation.
| Mandate Status | Mandatory |
| Model Type | Centralised exchange |
| Government Entity | FACE |
| Formats | Facturae |
| Infrastructure / Platform | FACE, among others |
| E-signature Required | Yes, qualified electronic signature |
| Key Deadlines | No upcoming deadlines |
| AR Mandatory | Yes |
| AP Mandatory | Yes |
| Peppol Available | No |
| Domestic Transactions | Yes |
| Cross-border Transactions | No |
| Archiving Period | 6 Years |
| Archiving Abroad | Yes |
Country Situation
The mandatory B2B electronic invoicing system in Spain represents a structural transformation of commercial documentation, driven primarily by the "Ley Crea y Crece" (Law 18/2022) and technically regulated by Real Decreto 238/2026. The mandate applies to all entrepreneurs and professionals operating within the national territory and aims to reduce commercial late payments (morosidad), foster business digitalization, and improve tax transparency. To achieve this, the Spanish model utilizes a hybrid architecture where businesses can choose to exchange invoices through accredited private platforms, utilize the free state-managed Public Electronic Invoicing Solution (SPFE), or use a combination of both.
Under this new system, electronic invoices must be issued as structured data messages complying with the European EN 16931 semantic standard, using syntaxes such as UBL, Facturae, EDIFACT, or CII. A core requirement is that if businesses exchange invoices via private platforms, the issuer's software must simultaneously transmit a "faithful copy" (copia fiel) in UBL syntax to the SPFE to maintain a centralized state repository. Furthermore, the system mandates dynamic reporting of invoice statuses to actively monitor and combat late payments; the recipient of the invoice must formally communicate the commercial acceptance or rejection, as well as the exact date of full effective payment, within a strict four-day window.
The implementation timeline for this mandate is tiered based on a company's annual turnover, with the official countdown triggered by the entry into force of the final Ministerial Order on 1 October 2026. Large enterprises with an annual turnover exceeding 8 million euros belong to the first phase and must be fully compliant within 12 months, by 1 October 2027. Small and medium-sized enterprises (SMEs) professionals with a turnover of 8 million euros or less fall into the second phase, giving them 24 months to adopt core e-invoicing by 1 October 2028, and an extended 36-month period (until 1 October 2029) for self-employed professionals, and to implement mandatory invoice status reporting.
| Mandate Status | Announced |
| Model Type | Decentralised CTC and exchange (DCTCE), Centralised exchange |
| Government Entity | AEAT |
| Formats | UBL 2.1, CII (Cross Industry Invoice), Facturae |
| Infrastructure / Platform | SPFE |
| E-signature Required | – |
| Key Deadlines | 1 October 2026: The final Ministerial Order enters into force, triggering the countdown for all B2B e-invoicing compliance phases 1 October 2027: Large enterprises with an annual turnover over 8 million euros must issue and receive structured electronic invoices 1 October 2028: Small and medium-sized enterprises must issue and receive structured electronic invoices 1 October 2029: Small and medium-sized enterprises and self-employed professionals must begin the mandatory reporting of invoice statuses, including payments; and self-employed professionals must issue and receive structured electronic invoices |
| AR Mandatory | Yes |
| AP Mandatory | Yes |
| Peppol Available | No |
| Domestic Transactions | Yes |
| Cross-border Transactions | No |
| Archiving Period | 6 Years |
| Archiving Abroad | Yes |
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