Spain proposes phased rollout for mandatory e-invoicing and e-reporting

Spain has proposed a major overhaul of its B2B invoicing system, introducing mandatory e-invoicingElectronic invoicing - widely referred to as e-invoicing - is the exchange of a digital document between a supplier and a buyer. E-invoices are issued, transmitted and received in a structured data format that enabled automatic and electronic processing. They contain data in a machine-readable format so that an AP system can read an invoice without manual data entry, leading to faster and more efficient invoicing. and near real-time e-reporting under its Crea y Crece framework. The measures are still in draft form but set out a detailed direction of travel for businesses operating in Spain.

The current proposal outlines a two-wave implementation starting in October 2027, alongside a new digital reporting obligation and a hybrid infrastructure model combining public and private systems.

A public consultation on the draft order remains open until 8^th May.

Proposed rollout timeline

Under the draft schedule, obligations would apply in phases:

• 1 October 2027 – Large businesses with turnover above €8 million
• 1 October 2028 – All other taxpayers

Supporting milestones include:

• October 2026 – Proposed entry into force of the order
• August 2027 – Planned launch of the public e-invoicing platform
• October 2029 – Extension of payment status reporting to smaller entities

While structured, the timetable is considered ambitious, and some stakeholders have suggested that delays could still occur before final adoption.

Technical standards and system design

The proposal introduces a dual-model infrastructure for B2B e-invoicing including a free public platform operated by Spain’s tax authority (AEAT), and private e-invoicing providers, operating within a regulated “five-corner” exchange model.

The draft aligns with the European EN 16931 standard, using UBLUniversal Business Language is an international standard in XML format specifically designed for electronic documents. syntax and introducing strict data and validation rules.

Key proposed features include:

• A unique invoice identifier based on tax and invoice data
• Full validation with acceptance or rejection messaging
• End-to-end traceability for corrections and cancellations
• Restrictions on attachments and non-structured data

Private operators would be required to ensure interoperability, maintain data integrity, and apply secure digital signatures before transmitting invoices.

Scope and open questions

Some elements remain under review. In particular, the treatment of non-resident businesses registered for Spanish VAT is not fully clarified and may depend on the final wording of the regulation.

The proposal also sits alongside existing Spanish reporting systems such as SII, which would continue to operate in parallel, adding further compliance considerations.

Part of a wider EU direction

The proposal reflects broader EU policy developments under the VAT in the Digital Age (ViDAViDA or 'VAT in the Digital Age', is an EU initiative proposed by the European Commission that seeks to modernise and harmonise VAT processes for member states, by embracing new technologies. It is aimed at updating processes for the management of VAT, and reduce the VAT gap and fraud. The proposal also aims to address challenges in the area of VAT raised by the development of the platform economy.) initiative, which is pushing for greater adoption of structured e-invoicing and digital reporting across member states.

It also forms part of Spain’s wider effort to reduce its VAT gapThe difference between the amount of VAT revenue due to a tax authority and the amount actually collected, estimated at several billion euros annually, by improving transaction visibility and reducing opportunities for fraud.

Other EU countries, including Italy, have already introduced similar systems, with measurable reductions in VAT losses, and further mandates are expected across Europe in the coming years.

How we can help

As Spain’s proposed e-invoicing and e-reporting framework continues to evolve, many businesses will need to assess how their current systems align with the expected requirements.

We support businesses in preparing for these changes through readiness workshops designed to assess current invoicing and ERPEnterprise resource planning (ERP) is a type of software that organisations use to manage main business processes. capabilities. You can find more details about our services here.

With timelines still subject to confirmation, early planning can help reduce implementation risk and avoid last-minute system changes once requirements are finalised.