As you may be aware, the Spanish government has undergone multiple revisions of the draft law in accordance with the implementation timeline that has been postponed. The most recent iteration of the draft law was made public in June 2023 and included certain technical clarifications; however, it is important to note that it has not yet received official approval from the government. Unofficially, the delay in enforcing the obligation of B2B e-invoices can be attributed to the uncertainty surrounding the political process in Spain.
As of now, the anticipated timeline for the implementation of the new e-invoicing mandate has been extended, with expectations that it will not come into effect until at least the early months of 2025. Prior to initiating the implementation process, crucial technical details still need to be addressed, including the establishment of a sample file format and the documentation of APIs (Application Programming Interfaces). In light of these forthcoming details, we, at SNI, are actively engaged in the ongoing development of our e-Invoice solution, aligning with the strategic milestones outlined in our roadmap.
The most important points in the latest draft law:
- Accepted Electronic Invoice Formats; UN/CEFACT XML, Invoice and credit note UBL messages, and EDIFACT.
- Use of electronic signature for integrity and authenticity when exchanging invoices through private service providers.
- Requirement for a unique code on all electronic invoices containing the supplier’s Tax identification number and issuance date.
- Recipients must approve or reject e-Invoices within 4 days of receipt, with payment status changing upon response.
- Entrepreneurs and professionals with an annual turnover of over €8 million face a 12-month timeline for compliance.
- The remaining taxpayers have a 24-month deadline for compliance.
- The Royal decree comes into effect 12 months after publication in the Official Gazette of the State.
- First 12 months: Invoices generated in electronic format should be sent with a PDF file to ensure legibility for recipients not yet compliant.
- 36 months after publication: Obligation on invoice statements applies to entrepreneurs with an annual turnover of less than €6,010,121.04.
- 48 months after publication: Obligation on invoice statements applies to professionals with an annual turnover of less than €6,010,121.04.