ALL newsletters (so far) on the draft regulations on the electronic invoicing (e-invoicing) regulations

On June 15, 2023, the Ministry of Finance published for consultation a draft of electronic invoicing (e-invoicing) regulations:

English version (Unofficial translation)

• TEXT OF THE DRAFT ROYAL DECREE DEVELOPING LAW 18/2022, OF SEPTEMBER 28, ON THE CREATION AND GROWTH OF COMPANIES REGARDING ELECTRONIC INVOICING BETWEEN COMPANIES AND PROFESSIONALS

The Agency is inviting feedback on the draft regulations by 10 July 2023.

Summary

• Electronic invoicing will be mandatory after 12 months of the publication of the royal Decree in the Official Gazette of the state.
• The receiver of the invoice (buyer) will have the obligation to inform his supplier about the acceptance, rejection, and payment of the invoice. Invoice status must be sent within 4 days.
• Companies will have the option of using the public billing portal or private service providers to exchange invoices.
• 4 invoice formats will be authorized: UBL, CII, EDIFACT and Facturae. When using the public invoicing portal, the Facturae format is mandatory.
• The use of an electronic signature is compulsory if invoices are exchanged by using private service providers.
• The creation of a human-readable version of the invoice will be mandatory during the first 12 months of the entry in force of the regulation.
• When companies use private service providers to exchange invoices, a copy of the invoice must be sent to the public invoicing portal.
• The invoice number must include the tax identifier of the company.
• Point-to-point interoperability is mandatory between all private service providers, and an operator must accept all requests for interoperability
• Interoperability between service providers is free of charge
• Private Service provider requirements: ISO/IEC 27001, secured connection protocols, ability to operate an electronic signature, process the 4 required formats, service continuity plan, 99% service availability, 24×7 support services, ensure data governance and security, interoperability.
• The public portal will extract the invoicing data and payment data to monitor the compliance

Newsletters from consultants

• Sovos: B2B E-invoicing Draft Regulation Published
• KPMG: Draft e-invoicing regulations published
• Kamila Ferhat: Draft of the Spanish e-invoicing regulation – A summary
• Global E-Invoicing News: Invoicing Revolution in Spain: New Royal Decree on Electronic Invoices and B2B Obligations
• Deloitte: Mandatory electronic invoicing in B2B operations – Draft of the Royal Decree Project by which the obligation of electronic invoicing is developed
• Pagero: Spain has released further information regarding the upcoming B2B mandate
• TPA: Spain Updates Draft Regulations for Proposed B2B E-Invoicing Regime
• VATCalc: Spanish mandatory B2B e-invoices draft technical specifications and regulations