Invoices issued by recipients or authorized third parties, known as “self-billing invoices,” are a type of commercial document that has long been a source of uncertainty for Spanish businesses. Specifically, in recent years, these invoices have prompted considerable discussion among companies due to questions about how the Verifiable Invoice Issuance System, VERI*FACTU, affects their issuance.

In fact, in February 2025, a response was published to a binding consultation whose interpretive criteria required that self-invoices be issued through VERI*FACTU, even for companies using the Immediate Supply of Information (SII) system. However, after the approval of Royal Decree 254/2025 just a few months later, this obligation was annulled.

This type of invoice has a number of features that must be understood to ensure regulatory compliance in issuing it and avoid potential irregularities. In this article, we explain how to create self-billing invoices, their advantages, and the obligations stipulated by current regulations.

Key takeaways

• A self-billing invoice is a document issued by the customer (or a third party) on behalf of the selling company to document a transaction.
  
• Although the selling company is not the one that issues a self-billing invoice, it is nonetheless responsible for the document’s validity for tax and legal purposes.
  
• Self-billing invoices can be used only if there is a prior agreement between the two parties involved in the transaction.
  
• The selling company must explicitly accept each self-billing invoice received.
  
• Self-billing invoices require a separate, dedicated numbering series, as well as a legal statement.
  

What is a self-billing invoice?

A self-billing invoice, usually known in Spain as an “autofactura,” is a commercial document issued by the purchasing party or by a third party contracted for such purpose. In other words, unlike other invoices, self-billing invoices are not issued by the selling company.

Although the invoices are issued by the buyer or an authorized third party, it’s the selling company that’s responsible for ensuring the documents comply with all relevant obligations, as stipulated in the Regulation Governing Invoicing Obligations (approved under Royal Decree 1619/2012).

Cases in which self-billing invoices are typically issued

Although any business that meets the legal requirements can use self-billing invoicing, Spanish companies typically use this mechanism in the following scenarios:

High-frequency transactions

Self-billing invoicing is common practice among companies that make recurring purchases of materials to manufacture their products, digital platforms that process mass payments, and professionals whose business model is based on recurring billing. This is due to one of the main advantages of self-billing invoices: streamlined billing procedures. For this reason, self-billing invoices are also frequently used in B2B marketplaces that handle a high volume of transactions between suppliers and customers.

If you run a B2B marketplace platform and have reached an agreement with the selling companies to issue self-billing invoices on your behalf, it’s likely that the sellers’ goal is to expedite payment collection. To further optimize this process, you can process customer payments through your platform using a multiparty payment system that captures the payment, retains your commission, and sends each seller their funds. For example, with Stripe Connect, business customers can use the most popular payment methods in B2B environments (such as SEPA transfers), while suppliers receive their funds instantly.

Goods pending inspection

Sometimes, the exact amount payable for goods can be determined only after they’ve been inspected. This situation is common, for example, among professionals who buy perishable food products whose weight and quality vary with each delivery. By issuing self-billing invoices that reflect the information on the delivery notes, data integrity is ensured, and the need to issue corrective invoices is avoided—another key advantage of self-billing invoices.

Companies subject to strict audit requirements

As with businesses receiving goods pending inspection, companies subject to strict audit requirements often use the mechanism of self-billing to avoid discrepancies. By issuing the invoices themselves, they ensure that the amounts paid to suppliers exactly match the goods received, thereby avoiding issues in the subsequent audit process.

Purchases of foreclosed assets

When an asset is foreclosed upon (i.e., seized from an individual or company for the purpose of sale) and a business acquires it through an auction, it’s common for the party subject to the seizure to be unwilling to issue an invoice. In such cases, Spanish regulations allow recipient-issued invoicing—as stipulated in the fifth additional provision of Royal Decree 1624/1992—and establish a time period of seven days for sending a copy of the self-billing invoice to the selling party.

Regulated sectors

Current legislation provides for several scenarios in which self-billing is mandatory, such as the sale of electricity. For example, the system operator is responsible for issuing, on behalf of the producers, self-billing invoices that reflect the exact consumption figures.

Differences between self-billing invoices and regular invoices

If you voluntarily opt for recipient- or third-party-issued invoicing, it’s important to understand the differences between regular invoices and self-billing invoices in order to avoid penalties for content errors when issuing either of these documents. Here’s a summary of the differences between these two types of invoices so you can prepare them correctly:

• Physical issuer
  The physical issuer of a self-billing invoice might be the recipient of the transaction or, in some cases, an authorized third party contracted for this purpose. In contrast, regular invoices are always physically issued by the seller.

• Identification
  With a self-billing invoice, the selling company is identified as the issuer on the invoice, even though the actual issuer might have been the customer or a third party. In contrast, with a regular invoice, it’s always the seller that physically issues the document. This means that the identifying information on a regular invoice does correspond to that of the actual issuer of the document.

• Prior agreement
  Since self-billing invoices are prepared by the recipient or a third party, it’s necessary for an agreement to have been reached in advance with the selling company. However, no authorization is required to issue regular invoices.

• Express acceptance
  The selling party must expressly accept each self-billing invoice received. In contrast, regular invoices do not require formal acceptance to be valid.

• Legal responsibility
  Whether issuing regular invoices or receiving self-billing invoices, the responsibility for ensuring that these documents meet legal requirements always lies with the selling company. In the case of regular invoices, since the seller is the party physically issuing the document, there is no room for doubt regarding their liability. However, a key difference with self-billing invoices is that, although the party physically issuing the document is the recipient or a third party, the selling company is ultimately responsible for the integrity and legality of the content, since the invoices are issued on its behalf.

• Legal statement
  Self-billing invoices issued by the recipient (rather than a third party) must contain the legal statement “invoiced by the recipient”; a regular invoice does not require any specific notation other than “invoice.”

• Numbering series
  Self-billing invoices require a separate, dedicated numbering series, while regular invoices follow the selling company’s standard sequential numbering.

Legal requirements of self-billing invoices

The Regulation Governing Invoicing Obligations and the Value-Added-Tax (VAT) Law establish the legal requirements for the buyer or an authorized third party to issue an invoice on behalf of the selling company. We’ve prepared a summary of the obligations covered by the regulation and the VAT Law:

• Agreement between the two parties
  The selling party must expressly authorize the customer or the contracted third party to issue invoices. The agreement must be formalized before sales take place and must specify which transactions will be subject to self-billing invoicing.

• Acceptance by the seller
  Once a self-billing invoice has been issued, the seller needs to accept the document after verifying that it complies with the agreed-upon conditions and contains no errors in content.

• Identification of the selling party
  Although the party physically issuing the self-billing invoice could be the recipient or a third party, for tax and legal purposes, the selling company is the entity responsible for the document. Therefore, the issuer must enter the seller’s identifying information.

• Legal statement
  If the invoice is issued by the recipient of the transaction, it must contain the statement “invoiced by the recipient” to be valid for tax and legal purposes; however, no legal statement is required if the issuer is an authorized third party.

• Dedicated numbering series
  Self-billing invoices require a separate, dedicated numbering series for each of the recipients or third parties that issue them.

• Copy of the self-billing invoice
  The issuer of a self-billing invoice must provide a copy to the selling party.

• VERI*FACTU
  When the VERI*FACTU regulations come into force (expected in January 2027), customers that issue self-billing invoices must generate them using software that complies with the new regulations, unless they opt in to the SII system. If your company is subject to VERI*FACTU regulations, you can ensure compliance by using Invopop, one of the apps available on the Stripe App Marketplace. This electronic invoicing platform was developed in Spain and enables the issuance of self-billing invoices in accordance with VERI*FACTU regulations.

• VAT record books
  The regulations specify that, regardless of who issues invoices (even if it’s the customer or a third party), both the issuer and the recipient must record them in their respective books: the selling company in the “invoices issued” ledger and the customer in the “invoices received” ledger. In short, for recording purposes, the law makes no distinction between self-billing invoices and other invoices.

Example of a self-billing invoice

Let’s see a practical example of a self-billing invoice: RocketPaper, a wholesale stationery company, decides to sell its products online through BeCopy, a B2B marketplace specializing in copy shops.

The high volume of sales through the marketplace makes the administrative management of invoicing difficult and causes delays in payment collections. Therefore, RocketPaper reaches an agreement with BeCopy for the marketplace to issue invoices on its behalf.

After reaching this agreement, each time a customer buys a product through BeCopy, the marketplace will issue a self-billing invoice on behalf of the selling company. The invoice must include both the mandatory information required for any invoice in Spain and the specific information applicable to self-billing invoices:

• Date of the self-billing invoice
  
• Invoice number from a numbering series dedicated to the third party issuing the self-billing invoice
  
• Legal statement, if the self-billing invoice is issued by the recipient (not mandatory if issued by an authorized third party, as in this example)
  
• Issuer details, i.e., the name or business name, Tax Identification Number (NIF), and address of the selling company (even if the issuer is actually the customer or a third party)
  
• Recipient details, i.e., the customer’s name or business name, NIF, and address
  
• Description of the transaction, including the unit price and any applied discounts
  
• Total taxable base
  
• Tax rate and tax liability
  
• Total amount due
  

In this case, the self-billing invoice is not prepared by the recipient of the transaction, but is issued by an authorized third party, so it’s not mandatory for it to contain a legal statement.

However, because the numbering series needs to be unique and specific to the third-party issuer, RocketPaper enters “3P” to refer to “third-party invoicing” and “MKT” to distinguish the marketplace from other companies that might issue invoices on its behalf.

When BeCopy issues the self-billing invoice, it sends a copy to RocketPaper for verification and approval, thus turning the complex invoicing process into a simple data validation task.

FAQs about self-billing invoices