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Spain Released a Draft Regulation of the B2B e-Invoice Regime

Lately, The Spain’s State Tax Administration Agency (Agency Estatal de Administracion Tributaria) has published an updated draft of proposed e-invoicing for B2B transactions. Tax authority waiting for the comments until 10 July 2023. New draft law only covers companies and  self-employed entrepreneurs established in Spain. For non-resident entities, issuance of simplified e-Invoice is out of scope for now.

According to the new publication, there are several formats accepted as a electronic invoice as follows; 

  • UN/CEFACT XML as specified in the XML 16B (SCRDM- CII) 
  • Invoice and credit note UBL messages which are defined in ISO/ IEC 19845:2015
  • EDIFACT according to ISO 9735 standard
  • Facturae message, in the version for invoicing between businessmen and professionals in force at any given time. 

PDF invoices are no longer acceptable as an electronic document.

The Spanish e-Invoicing system will also include the following important characteristics and requirements : 

  • When invoices are exchanged by using private service providers, electronic signature must be used to ensure integrity and authenticity (I&A).
  • A unique code will be required for all electronic invoices and contains the supplier’s Tax identification number and issuance date.
  • The recipients must be approved or rejected after getting the e-Invoices  ​and they have 4 days to respond​. With the coming response payment status also changed.


Requirements of being a Private electronic Invoice Exchange portal as follows;

  • ISO/IEC 27001 certification
  •  Use secure transmission protocols with AS2 or AS4 specifications.
  • Ability to operate a digital signature
  • Exchange e-Invoices in all accepted format
  • Ensuring service availability and having support resources that are available at all times
  • Ensuring free interconnection and interoperability with other platforms, also data governance and confidentiality must be ensured
  • Regarding the use of private service providers for exchanging invoices, sending a copy of the invoice to the public portal is obligatory 


The most remarkable and expected detail of the draft electronic invoice law  was the implementation timeline;

  • For the entrepreneurs and professionals with the annual turnover that is over €8 million the 12 months timeline will be applied and 24 months deadline will be applied to the remaining taxpayers. The Royal decree will come into effect 12 months after its publication in the Official Gazette of the State
  • First 12 months generated invoice in electronic format should be sent to the recipient with a PDF file for the recipient who has not yet entered into force to ensure legibility
  • 36 months after the publication in the official gazette of the state, the obligation on the invoice statements will apply to the entrepreneurs with annual turnover that is less than €6,010,121.04  and 
  • 48 months after the publication, it will apply to the professionals with annual turnover that is less than €6,010,121.04 


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