Spain is moving toward a fully digital VAT reporting ecosystem. On 29 September 2022, Spanish Congress passed the technical specification bill for mandatory eInvoicing in the private sector. This measure aims to reduce VAT fraud and close the tax gap.
The bill was further ratified on 15 June 2023, providing detailed specifications on:
- File formats
- Required taxpayer scope
- Verification of payment dates
- Minimum interoperability standards for eInvoice providers
- Security and device/ERP standardisation
Public Consultation and Clarifications (April 2025)
The Spanish Ministry of Economy completed a public consultation clarifying:
- Accepted eInvoice formats
- Mandatory payment data in credit/debit notes
- Tax point date requirements (start/end of periods)
- Confirmed 12-month notice period post-Ministerial Order before mandatory compliance begins
Accepted file formats (All EN 16931 compliant):
- CII (Cross Industry Invoice)
- UBL (Universal Business Language)
- EDIFACT
Submission channels:
- Directly to the AEAT (Spanish Tax Agency)
- Via a certified application or agent
Mandatory elements in eInvoices:
Every eInvoice must include:
- Electronic signature including, business VAT ID, invoice number and series
- Date of issue
- QR codes for traceability (software vendors must comply)
Security and interoperability:
Spain is enforcing minimum standards between different systems, including device and ERP protocols. All eInvoicing agents and software vendors must comply with the VERIFACTU protocol:
- From 30 July 2025: VERIFACTU protocol enforced for software vendors.
- From 1 January 2026: Taxpayers required to comply with VERIFACTU for eInvoice issuance and submission
Full compliance timelines (Expected):
2027 is the earliest expected date for large enterprises to comply with full eInvoicing mandate.
2028 is the earliest expected date for SMEs to comply.
Final compliance dates depend on the Ministerial Order of Development, which triggers a 12-month notice period before enforcement.
Operational model and consideration
Spain is likely adopting a 5-corner model for their eInvoicing system. Large enterprises already subject to real-time digital reporting (SII) and must adapt systems accordingly.
Business should:
- Review current invoicing software for VERIFACTU readiness
- Ensure electronic signature capability is in place
- Monitor announcements for the Ministerial Order triggering mandatory compliance
- Coordinate with ERP providers for EN 16931-compliant formats
- Prepare for interoperability, especially if using third-party platforms or agents
Key takeaway
Spain’s private sector eInvoicing mandate represents a major step toward digital VAT compliance. Early preparation is crucial for businesses of all sizes to meet VERIFACTU requirements, ensure system interoperability, and align with future Ministerial Orders.
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Authors
Lisa Dowling
Specialising in International VAT Compliance solutions, Lisa brings a wealth of knowledge and insight in her dealings with a host of international clients ranging from start-ups through to multinationals. With 21 years VAT experience behind her, Lisa has managed VAT compliance issues and solutions globally for over 11 years. Fintua have 12,000 + corporate clients in over 109 countries and many of these are members of the Fortune 500.
