Delays in Spain's Crea y Crece E-Invoicing Mandate Push Implementation to 2027 or Later
Spain's ambitious plans for a B2B e-invoicing mandate, part of the Crea y Crece initiative, are facing significant delays, pushing the timeline for implementation back to at least 2027. It is expected to roll out by July 2025 or early 2026; the postponement is mainly due to unresolved technical specification issues.
The country's tax authorities, the Agencia Estatal de Administracion Tributaria, have acknowledged the project's complexity, emphasizing the need to finalize the technical specifications before proceeding.
Spain’s E-Invoicing Implementation Plan
Concerns have been raised regarding the syntax design of the proposed system, suggesting that the details of the project are more complicated than initially anticipated. As a result, Spain aims to complete these technical specifications before potentially conducting a public consultation on them, followed by legislative approval. The expected model for the Spanish e-invoicing system is a five-corner approach, which is currently the most likely structure.
The proposed implementation will follow a phased approach. If the timeline holds, the first phase in 2027 will apply to large taxpayers with a turnover exceeding €8 million. The second phase, scheduled for 2028, will encompass all other taxpayers, marking a comprehensive adoption of e-invoicing across the country.
In addition, smaller businesses will likely face new obligations related to certified VERIFACTU electronic invoice software starting in January 2026.
European Commission's Feedback and Future Considerations
On May 6, the European Commission provided its backing for Spain's legislation (Real Decreto de desarrollo de la Ley 18/2022) that seeks to impose B2B e-invoicing. Their response to Spain's request for a derogation from the EU Directive confirms that the proposed legislation does not infringe upon EU law, allowing for a legal priority of e-invoices over traditional paper invoices.
However, Spain has yet to receive the necessary approval from the European Commission to mandate e-invoicing. There is also ongoing discussion around the EU's ViDA Digital Reporting Requirements, which propose a withdrawal of this approval requirement as soon as possible, pending endorsement from EU Finance Ministers. Spain may be cautious in advancing its domestic e-invoicing regime until further details about the ViDA July 2030 inter-community e-invoicing and digital reporting requirements are clarified.
As Spain navigates these challenges, businesses must remain vigilant and prepared for the eventual shift towards mandatory e-invoicing, ensuring they adapt to the changing landscape of invoicing regulations in the coming years.
There’s more you should know about e-invoicing in Spain – learn more about the new and upcoming regulations.
