The Spanish Ministry of Economic Affairs and Digital Transformation has announced a second public consultation on the forthcoming B2B e-invoicing mandate. This initiative aims to enhance citizen engagement in the regulatory development process before finalizing the framework.
The consultation focuses on articles and provisions that have been modified from the previous draft. By gathering feedback, the government seeks to refine the regulatory framework needed to implement mandatory B2B e-invoicing.
In April 2025, Spain’s Ministry of Economy completed its second public consultation on the Draft Royal Decree (Crea y Crece law), setting out the framework for the country’s mandatory e-invoicing system.
Key Updates from the Draft Regulations
- Shift to UBL syntax: Spain will abandon the Facturae format in favour of UBL, aligning with the EU’s ViDA initiative.
- Payment details clarified: Credit and debit notes must include detailed payment information.
- Defined payment terms: Invoices must show clear start and end dates for the payment period.
- VERIFACTU compliance: Invoices created on the public billing platform will meet Spain’s VERIFACTU requirements.
- Public copying process: Ensures invoices created on the public system can also flow through private networks.
- 12-month notice period: The mandate will only apply 12 months after the Ministerial Order is approved, meaning no start date before 2027.
Expected Implementation Timeline
- 2027: Large taxpayers (turnover above €8 million).
- 2028: All other taxpayers.
Spain is expected to adopt a 5-corner e-invoicing model, in line with broader EU developments.
What’s Still Missing?
- No technical specifications have been published yet, which will require another public consultation.
- An exact go-live date is still pending, but the earliest possible start is 2027.
For further details and participation guidelines, interested parties should refer to the Ministry’s official website. https://portal.mineco.gob.es/es-es/ministerio/participacionpublica/audienciapublica/Paginas/2-Audiencia-Proyecto-RD-establece-regimen-juridico-aplicable-factura-electronica.aspx
