Preparing for e-Invoicing Compliance
Spain’s e-Invoicing landscape is undergoing significant changes, shaped by the new draft regulation published on June 15, 2023, and the earlier “Crea y Crece” Law 18/2022, enacted on September 28, 2022. These legislative developments signal a major shift in how companies will handle invoicing, necessitating awareness and adaptation to the evolving regulatory environment.
Historical Context
The journey towards e-Invoicing in Spain began with Law 25/2013, which mandated electronic invoicing for contracts between companies and the state public sector. This initial step was built upon the invoicing regulation 1619/2012, which allowed for electronic invoicing where the recipient consented. The concept re-emerged strongly in 2022 with Law 18/2022, extending the obligation of e-Invoicing to B2B transactions and certain B2C transactions. However, this requirement will take effect one or two years after the publication of the regulatory framework, depending on the company’s turnover.
Key Elements of the New Regulation
The draft regulation from 2023 outlines several critical aspects:
- Scope of Applicability: The e-Invoicing mandate will apply to all entrepreneurs required to issue invoices for B2B activities, excluding those without a business presence or permanent establishment in Spain. Exceptions include simplified invoices, such as cash receipts.
- Platforms for E-Invoice Exchange: E-Invoices can be exchanged through either a public platform or a private platform that meets the necessary requirements. Private platform issuers must send a true copy of each invoice in Facturae syntax to the public platform.
- Reporting Requirements: Companies must electronically issue, receive, and report the status of e-Invoices (acceptance, rejection, or payment/collection) within a maximum of four calendar days from the status date.
- Invoice Formats: Accepted e-Invoice formats include:
- UN/CEFACT XML message applicable across industries.
- Invoice and credit note UBL messages (ISO/IEC 19845:2015 standard).
- Invoice EDIFACT message according to ISO 9735 standard.
- Facturae message.
Moving Forward
As Spain progresses towards full e-Invoicing adoption, businesses must prepare for significant operational changes. Staying informed about the latest legislative updates and understanding the compliance requirements will be crucial for seamless integration and leveraging the benefits of digital invoicing. The Ministry of Finance’s draft regulation from 2023 offers a preview of the future e-Invoicing landscape, emphasizing the need for businesses to adapt promptly.
