The Spanish government has officially announced a delay in the implementation of its Business-to-Business (B2B) e-invoicing mandate, pushing the expected start date back to 2027. This decision, revealed on October 1, 2024, comes after months of uncertainty surrounding the project’s timeline. Initially, the mandate was projected to take effect as early as July 2025, with some sources suggesting a possible delay to summer 2026. However, the complexity of finalizing the technical specifications needed for the e-invoicing legislation has led to a significant postponement.
Reasons for the Delay
The primary factor behind the delay is the slow progress in developing the technical framework required for the approval of the e-invoicing regulations. The Spanish tax authorities, Agencia Estatal de Administración Tributaria (AEAT), have encountered challenges in completing the syntax design and overall technical infrastructure for the mandate. The project has proven to be more intricate than anticipated, with these technical hurdles necessitating a longer timeline to ensure a seamless implementation.
Moreover, the Spanish government is expected to finalize the technical specifications before moving forward with any public consultation process. Only after this will the legislation be officially approved, further pushing the timeline back.
Revised Timeline for B2B E-Invoicing
Despite the delay, Spain remains committed to its original e-invoicing strategy, though with a revised schedule. Under the new timeline, the mandate will be rolled out in a two-phase approach:
- 2027: Large taxpayers with annual turnovers exceeding €8 million will be required to comply with the e-invoicing mandate 12 months after the official publication of the final regulations in the government’s official gazette.
- 2028: All other businesses, regardless of size, will need to adhere to the e-invoicing requirements 24 months after the publication of the final regulations.
Initial Expectations and the Complexity of Implementation
There had been hope earlier that the B2B e-invoicing mandate could be implemented by July 2025 or, at the latest, in summer 2026. However, given the complexity of the project and the need to address technical issues like the e-invoice format, the Spanish government has opted for a more cautious approach. Officials are prioritizing the completion of the technical specifications, which will ensure the infrastructure is robust enough to support the large-scale adoption of electronic invoicing across all sectors. This methodical approach will likely involve a public consultation once the technical details are finalized, further delaying the legislative process.
Implications for Large and Small Businesses
The postponement will give businesses more time to prepare for compliance with Spain’s e-invoicing requirements. Larger companies, particularly those with turnovers exceeding €8 million, will now have until 2027 to fully comply with the mandate. Meanwhile, smaller businesses will benefit from an extended deadline, with e-invoicing becoming mandatory for them in 2028.
In the meantime, Spain has made progress on another front. The government has already certified the VERIFACTU electronic invoice software for small businesses, which will become mandatory in January 2026. This separate regulation ensures that smaller enterprises adopt compliant e-invoicing systems before the full-scale implementation of the B2B mandate.
Conclusion: Spain’s New E-Invoicing Roadmap
While the postponement to 2027 is significant, it reflects Spain’s commitment to ensuring that the B2B e-invoicing system is technically sound and capable of handling the complexities of large-scale adoption. The delayed timeline allows both the government and businesses to adequately prepare for the transition to a fully digital invoicing framework, reducing the risk of errors or disruptions.
Businesses are encouraged to stay informed about the upcoming developments and ensure they are ready for compliance when the final regulations are published. With 2027 set as the new starting point for large taxpayers and 2028 for smaller businesses, the Spanish government has laid out a clear roadmap for the eventual roll-out of mandatory e-invoicing across the country.
Key Dates:
- 2027: Large taxpayers (turnover over €8 million) must comply 12 months after the publication of the final regulations.
- 2028: All other taxpayers must comply 24 months after the publication of the final regulations.
- January 2026: Smaller businesses must comply with VERIFACTU electronic invoice software obligations.
Stay updated on the latest developments to ensure a smooth transition to e-Invoicing compliance in Spain.
