Electronic invoicing, or e-invoicing, has been experiencing strong growth in Spain for many years; however, its expansion has accelerated significantly since 2022, as indicated by the “12th Electronic Invoicing Study” by SERES, a digital transformation software provider. By passing the Create and Grow Law that year, the country set the stage for the future obligation to issue e-invoices.

This guide analyzes the key considerations once the country announces the implementation schedule for mandatory electronic invoicing.

What’s in this article?

• What is electronic invoicing?
  
• What are the benefits of electronic invoices?
  
• Who is subject to mandatory electronic invoicing?
  
• Legal requirements of mandatory electronic invoicing in Spain
  
• When will electronic invoicing become mandatory?
  
• Types of electronic invoices accepted in Spain
  
• Penalties for not complying with mandatory electronic invoicing in Spain
  
• Steps to implement electronic invoicing in Spain
  
• FAQs about mandatory electronic invoicing in Spain
  

What is electronic invoicing?

Electronic invoicing means managing invoices entirely in digital form. Spanish regulations also include some specific legal requirements, as evidenced by the use of certain file formats and certified tools.

Particularly, software that complies with the rules on compulsory electronic invoicing in Spain must be able to share the information contained in online invoices with the tax authorities in real time using electronic means, such as VERI*FACTU.

Although e-invoices contain the same details as the traditional, paper-based method, the Spanish Tax Agency (AEAT) can instantly validate them, making records automatically traceable. When electronic invoicing becomes mandatory in Spain, it will be the only method that legally validates transactions for tax purposes.

What are the benefits of electronic invoices?

In addition to complying with future e-invoicing regulations, working with a digital system has some direct benefits:

• Fewer errors
  With traditional methods, errors can occur, such as incorrectly entering designated invoice details—a frequent issue when invoicing a client for the first time, and which can lead to failed payments. Electronic invoicing platforms enable the automation of data entry, ensuring that information is always accurate and up-to-date.

• Time savings
  Automating a large part of this process—e.g., generating or sending invoices—means documents reach recipients sooner, and it ultimately becomes a beneficial payment optimization strategy. In 2024 alone, Spanish companies saved more than 2.3 million hours managing issued and received invoices thanks to these systems.

• Savings in administrative costs
  Reducing the hours spent managing invoices also lowers administrative costs. The savings of local businesses that implemented e-invoicing platforms exceeded €4.3 billion in 2024.

• Greater sustainability
  Electronic invoicing eliminates the need for printing paper versions. Along with avoiding the need to store a multitude of physical documents, the issuance and receipt of invoices electronically in Spain resulted in paper savings equivalent to more than 31,000 trees.

Who is subject to mandatory electronic invoicing?

E-invoicing will be mandatory for all companies and self-employed individuals who conduct transactions with other entrepreneurs or professionals. That is, invoices for all B2B activities have to be issued digitally. Businesses need to send electronic invoices for transactions with individual customers (B2C) only when one of the following two conditions applies:

• The customer explicitly accepts or requests to receive electronic invoices
  
• The invoicing company qualifies as a travel agency, provides transportation services, or engages in retail trade, and the parties enter into the contract digitally
  

Furthermore, there are some cases in which it isn’t necessary:

• Provincial regime: Companies and self-employed individuals are subject to this regime when their registered office is in the Basque Country or in Navarre. In these autonomous communities, alternative mandatory e-invoicing regulations known respectively as TicketBAI and BATUZ apply.

• Simplified invoices: These apply to operations documented with simplified invoices, generally for amounts up to €400 (including value-added tax [VAT]) or for corrective bills; in particular instances, such as retail trade, the limit rises to €3,000.

• Voluntary invoices: These refer to transactions that are documented with invoices despite not having the obligation to do so. For example, a retail store is only required to provide a receipt to a customer for purchases under €3,000; still, it could also voluntarily generate an invoice. In this case, the company would still be allowed to issue a paper version instead of using the mandatory electronic system.

Legal requirements of mandatory electronic invoicing in Spain

The Create and Grow Law imposes the most stringent legal requirements for electronic invoicing in Spain, although other laws complement the regulatory framework. The following are some of the most important obligations:

• Reporting on invoice status
  Both parties need to report on the status of their invoices: issued, received, paid, or overdue. To illustrate, when paying suppliers, you must explicitly state that you have paid the invoices.

• Providing free copies
  The person or company getting an e-invoice needs to be able to request a copy at no additional cost. This has to be provided free of charge for a span of four years from the date it was created. This period aligns with the obligation to store each invoice, as stipulated in Article 29.2 of the General Tax Law.

• Allowing access to prior invoices
  Revoking consent to receive electronic invoices cannot remove the right to access prior ones. Additionally, the termination of a contractual relationship does not mean that invoices issued during the contract term are no longer accessible.

• Sending electronic invoices to the AEAT
  Users need to use the free public e-invoicing tool developed by the AEAT or a certified application (with the features introduced by the anti-fraud law) to send invoices to the agency. If you choose to work with third-party software, the program must automatically send a digital copy of each document to the AEAT.

• Increase in companies required to issue electronic invoices
  The regulations permit the list of companies obliged to invoice digitally to expand if they maintain frequent online communication with customers and create a high volume of invoices.

When will electronic invoicing become mandatory?

Mandatory e-invoicing takes effect when the final regulations of the Create and Grow Law are approved, currently slated for publication by the end of 2025. From then, two different periods apply, depending on turnover:

• One year: Companies and self-employed individuals with a turnover greater than €8 million
  
• Two years: Companies and self-employed individuals with turnover less than €8 million
  

Moreover, the anti-fraud law requires the use of computer invoicing systems (SIF) by the following deadlines:

• January 1, 2026: Companies that pay corporate income tax (IS) by filling out Form 200 or Form 202
  
• July 1, 2026: All other professionals and self-employed individuals
  

In 2026, using certified invoicing tools will become obligatory. Nevertheless, submitting these documents in real time to the AEAT through VERI * FACTU will not yet be necessary, as the definitive rules are still pending.

Types of electronic invoices accepted in Spain

National rules distinguish between two main types of electronic invoices: structured and unstructured. Although both can be transmitted digitally (e.g., from an invoicing platform or by email), their treatment and usefulness for tax purposes vary considerably. Let’s take a look at more details on these:

Structured electronic invoices

These kinds contain data organized so that computer systems—on the sender and recipient sides—can process records without manual intervention. Structured e-invoices are especially useful because they enable the automation of creation, payment, and recording, thereby minimizing manual errors and reducing the time spent managing them.

The latest draft of the Royal Decree indicates the four file types accepted for generating structured electronic invoices:

• Facturae: The AEAT’s own format
  
• Universal Business Language (UBL): International Extensible Markup Language (XML)–based standard
  
• Electronic Data Interchange for Administration, Commerce and Transport (EDIFACT): Common format in large organizations and industries with high turnover
  
• Other XML-based formats that meet the requirements
  

Unstructured electronic invoices

This type resembles traditional invoicing methods and contains information in a format that cannot be processed automatically. The following are some of the most common file types:

• PDF without structured metadata
  
• Scanned images of paper invoices (e.g., in JPEG or PNG)
  

Despite being digital documents, they still require manual processing, which introduces a designated margin of error and slows down their management. They could still be applicable in particular contexts, but this type won’t be permitted for B2B transactions once the definitive text of the Create and Grow Law takes effect.

Penalties for not complying with mandatory electronic invoicing in Spain

To ensure compliance with the European Union’s electronic invoicing requirements, the AEAT will impose severe penalties on companies and self-employed individuals who fail to invoice electronically.

If organizations block customers from getting e-invoices or prevent them from accessing prior ones, they will receive a warning. That said, if there is a repeat offense or the violation is considered to be serious—e.g., obstructing an inspection—the fine can reach €10,000.

Steps to implement electronic invoicing in Spain

If you are required to invoice electronically, it’s important to do so before the deadline set by the final regulations to avoid penalties. Below are the steps to roll out mandatory e-invoicing in Spain:

• Choosing an approved software
  Consult the list of approved electronic invoicing software. All programs must be able to exchange information with others and with the AEAT’s system itself at no extra charge. The tool has to allow for the management of electronic invoices and let customers access them for free reading, downloading, or printing. Furthermore, if a user chooses to stop receiving e-invoices, the software needs to offer a free and intuitive process for withdrawing consent. Suppose you use Stripe Payments to process your online transactions. In that case, you can automate all your e-invoicing needs with Invopop: a billing solution developed in Spain, designed to comply with the AEAT's VERI * FACTU system and all other relevant European regulations. From the Stripe App Marketplace, you can access this and a wide range of solutions that integrate easily with your payment platform.

• Establishing the channel for submitting invoices
  Once the software launches, select the channel for submitting invoices. For instance, in the case of individuals, email is a common means of communication, which requires obtaining prior consent. In B2B environments, it is frequent to utilize business communication channels, such as electronic data interchange (EDI), enabling automatic invoice processing and B2B payment automation.

• Creating invoices
  Electronic invoices need to show the issue date, the Tax Identification Number (NIF), and personal details of the issuer and the recipient, as well as the invoice number and a description of the transaction. The content must be stored in structured files using one of the formats permitted by the final text of the law. The types listed in the draft Royal Decree are XML, UBL, EDIFACT, and Facturae.

• Submitting invoices to the AEAT
  The software’s approval ensures that it is compatible with the VERI * FACTU system, whereby invoice records are transmitted automatically, without any manual intervention, as they are generated.

• Keeping invoices
  Issuers are required to retain all e-invoices for a minimum of four years. If the AEAT sends any request, you must be able to recover any documents generated during that timeframe immediately.

FAQs about mandatory electronic invoicing in Spain

Is electronic invoicing mandatory for transactions with individuals?

Although many assume electronic invoicing applies exclusively to B2B payments, certain B2C transactions also require digital forms. For example, if an individual customer explicitly opts in or requests to receive e-invoices, the company must issue them. Similarly, in the transportation, travel agency, and retail industries, electronic invoices are necessary when parties enter into contracts digitally.

Is electronic invoicing mandatory for self-employed individuals?

Yes, it is required for both companies and self-employed individuals. As stated in Article 12 of the Create and Grow Law, electronic invoicing is compulsory for all professionals who sell their products or services to other entrepreneurs or professionals. If you are self-employed, use of a certified application starts as of July 1, 2026. In addition, automatic submission of documents to the AEAT and the remaining obligations apply two years after the definitive text of the law is approved (which is expected by the end of 2025).

Does a company need to suspend electronic invoicing if real-time communication with the AEAT is interrupted?

No, the company has to continue invoicing electronically when it cannot communicate with the AEAT. In the event of a computer or network failure affecting real-time communication, the company must continue to do so if it has the capacity—e.g., if an incident involves the AEAT’s server but the company still has internet access. If electronic invoices are not submitted instantly, users must send them promptly and mark an “S” in the “Incident” field.

Which electronic invoice formats are mandatory?

While it remains legal to send invoices in unstructured digital formats—such as PDF files or scanned images—these won’t be permitted for B2B transactions when the final text of the Create and Grow Law takes effect.

From that moment on, only structured formats that allow for automated invoice processing will be valid. Per the latest draft of the Royal Decree, the recognized types will be Facturae, UBL, EDIFACT, and other XML-based alternatives that meet the technical criteria established by the AEAT.