Electronic Invoicing Becomes Compulsory in Spain

Published on 20 December 2023

In Spain, Law 18/2022, on the creation and growth of companies, established the obligation to issue electronic invoices in all business-to-business transactions. This obligation was implemented in more detail by the new invoicing regulation published on 6 December 2023 in the Spanish State Gazette (BOE), mainly aimed at modernising and digitalising accounting, invoicing and management processes for entrepreneurs, with a special focus on SMEs, microenterprises and freelancers.

This movement towards digitalisation seeks to ensure the interconnection of IT systems, compatible with customers, suppliers and the public administration as well as to improve the quality of information.

The new regulation should be seen as part of a broader context – Tax Compliance by Design –, promoted by international organisations such as the OECD and the European Union. Its goal is to ensure an efficient connection between taxpayers and the tax administration in a digitalised environment, in order to reduce costs and increase competitiveness.

The regulation establishes technical requirements for electronic invoicing systems, with a focus on the integrity, retention, accessibility, readability, traceability and inalterability of the invoices and their underlying data. IT systems have to meet technical specifications to ensure compliance with tax regulations, however, the corresponding ministerial order on the technical aspects of IT systems has not been passed yet. Nevertheless, taxpayers must have their IT systems adapted and operational by 1 July 2025.

The regulation also addresses the issuance of electronic invoices and establishes measures to prevent tax fraud. The chosen system must automatically generate a record (data) of the respective invoice at the same time as or prior to the issuance of each invoice. This also applies to credit notes to cancel incorrect invoices, so it is essential to pay special attention fulfilling the requirements for correction invoices for VAT purposes.

Grants and financial assistance are available to help companies and freelancers adapt to these new digital requirements. Interested companies can register until 31 December 2024 under this link. These financial programs are available for the following digital solutions:

  • Website and internet presence
  • E-commerce
  • Social media management
  • Client management
  • Business intelligence and analytics
  • Process management
  • Electronic invoicing
  • Virtual office services and tools
  • Secure communications
  • Cybersecurity

If your company needs help with the changes in electronic invoicing or with this new digital adaptation, please do not hesitate to contact us.