SUMMARY
INDEPTH ANALYSIS
E-Invoicing in Spain (Mandatory Electronic Invoicing)
- Implementation Timeline:
- B2G (Business-to-Government): January 2015 – Spain made e-invoicing mandatory for all suppliers issuing invoices to the public sector. Invoices to public administrations must be submitted through the government FACe platform in the standard FacturaE XML format with a digital signature. [avalara.com]
- B2B (Business-to-Business): September 2022 – Spain’s “Crea y Crece” Law 18/2022 was enacted, mandating electronic invoicing for all B2B transactions between companies and freelancers in Spain. This law established the obligation but did not immediately enforce it; implementation depends on technical regulations. [avalara.com]
- June 2023: Draft Royal Decree published outlining the technical framework for B2B e-invoicing; public consultation began. [avalara.com]
- March 2025: A revised draft regulation was released (and submitted to the EU for review) with updates – including adoption of UBL format and eliminating most paper invoice exceptions. [avalara.com], [avalara.com]
- Enforcement (Planned): The mandate will take effect in a phased manner after the final regulation is approved. Large businesses (annual turnover > €8 million) must comply 12 months after the regulation is published, and all other businesses 24 months after. As of late 2024, the government announced a delay: the expected start for large companies is in 2027, and for SMEs by 2028, to allow time for technical readiness. (This is a postponement from earlier expectations of 2024–2025.) [ey.com], [ey.com] [rtcsuite.com]
- Transactions in Scope:
- The B2B e-invoicing mandate will apply to all invoices issued in Spain between VAT-registered businesses (domestic B2B transactions). This includes sales of goods or services where both supplier and customer are entrepreneurs/professionals in Spain. [ey.com]
- B2C: The law does not generally require e-invoices for B2C transactions. Consumers can still receive paper receipts/invoices by default. However, large companies must offer customers the option to receive an e-invoice and cannot deny access to it (this was introduced by Law 18/2022 to encourage e-invoicing uptake). [factursystem.com]
- Cross-border: Invoices between a Spanish business and a foreign entity are not explicitly under the domestic mandate. Cross-border B2B e-invoicing will follow EU rules (e.g. the upcoming 2028 EU requirement for intra-EU e-invoices under ViDA). Spain’s mandate for now focuses on domestic transactions.
- Existing B2G: All invoices to public authorities (B2G) are already required to be electronic (FacturaE via FACe) since 2015, as noted. [avalara.com]
- Taxable Persons in Scope:
- All entrepreneurs and professionals established in Spain who engage in B2B transactions will be required to issue and receive electronic invoices once the system is in force. This covers companies (including permanent establishments of foreign companies in Spain) and self-employed individuals. [ey.com], [ey.com]
- The obligation will roll out first to large taxpayers (turnover > €8M) and later to SMEs and freelancers as described in the timeline. No industry exemptions are expected – virtually all sectors must comply (some very specific invoice types might be excluded by regulation, but generally it’s broad-based). [rtcsuite.com] [ey.com]
- Businesses in the Basque Country or Navarra that fall under regional tax systems will follow their regional mandates (see Regional Differences below) – but if they are subject to the state VAT system, the national e-invoicing rules apply as well.
- Data to be Provided on E-Invoices:
- E-invoices must contain the full set of invoice data required by VAT law (issuer and recipient details, tax ID numbers, invoice number, date, description of goods/services, taxable amounts, VAT amounts, etc.), same as a paper invoice.
- In addition, the Spanish draft requirements introduce specific traceability metadata: each electronic invoice should include a unique invoice identifier and a secure hash of the invoice (to link with the previous invoice, creating an audit trail). They also will include a QR code on each invoice for easy verification by the recipient or authorities. [bdo.global]
- Invoice issuance systems must capture the exact timestamp of issuance and transmit that along with the invoice data. The status of the invoice (paid, pending, rejected) may also need to be tracked: the regulation expects buyers to report back certain statuses (payment and acceptance) to help monitor payment delays. [ey.com]
- Veri*Factu compliance: Under Law 11/2021 and RD 1007/2023, invoicing software must be certified (Veri*Factu) to prevent fraud. This means the software should generate an immutable record for each invoice and presumably send a copy of invoice records to the tax authorities. Businesses not already using the SII system will be obligated to use such certified systems. Veri*Factu records include digital signatures and logs of any data exports. (Notably, taxpayers who keep VAT records via SII are exempt from this certified software mandate, since SII already provides control.) [bdo.global] [bdo.global], [bdo.global]
- Format of E-Invoices:
- Spain’s standard is the FacturaE XML format (based on XML schemas, currently version 3.2.2) which is already used for B2G invoicing. FacturaE includes an XML structure and requires an XAdES electronic signature. This format will continue to be accepted. [avalara.com]
- The new draft B2B e-invoicing regulation is aligning with European standards, so it explicitly allows UBL (Universal Business Language) and CII (Cross Industry Invoice) formats as well. UBL is an XML format compatible with the EU standard EN16931, which is likely to be central under the EU’s ViDA reforms. Spain’s tax authority plans to move its public e-invoicing platform towards UBL format for compatibility. [avalara.com], [ey.com] [ey.com]
- In practice, businesses may use private e-invoicing platforms or software that output invoices in the accepted formats. If two companies exchange invoices via private platforms, a copy of each invoice must still be sent to the Spanish Tax Agency’s central e-invoice system (a public platform) to serve as an official repository. The government is building this public platform to ensure it receives the data in real-time. [ey.com], [ey.com]
- Transmission & Due Dates:
- Real-time or near-real-time submission is expected. The goal is that as soon as an invoice is issued, its data is available to tax authorities. The draft rules indicate that if businesses exchange invoices through private platforms, an automatic copy of each invoice must go to the Tax Agency’s system immediately. This suggests no lengthy delay is allowed; effectively, reporting is instantaneous upon issuance (similar to a continuous transaction control model). [ey.com]
- Currently, under the B2G system, invoices are submitted to the FACe portal at the time of issuing to the government client. For B2B, the exact deadline (e.g. within X days) will be set in the final regulation, but “immediate submission” is the principle. Many expect a tolerance of perhaps a couple of days if at all, but as of now assume immediate electronic issuance = immediate reporting.
- Additionally, recipients will have obligations to report invoice status changes (like payment) within a certain time, to enable monitoring of payment terms (one of the aims of the law is to combat late payments). [ey.com], [ey.com]
- Penalties for Non-Compliance (E-Invoicing):
- Spain has defined penalties in Law 18/2022 for failures related to electronic invoicing: [factursystem.com]
- Failing to issue an invoice in electronic format when required can incur a fine of up to €3,000 per invoice. [factursystem.com]
- Not properly storing or archiving e-invoices (which must be kept for the statutory period) can be fined up to €6,000. [factursystem.com]
- Refusing to provide an e-invoice to a customer who is entitled to one, or denying access to the e-invoice (for example, if a customer or former client requests a copy), is punishable by up to €10,000. [factursystem.com]
- More general non-compliance with accounting obligations related to e-invoicing (for instance, using systems that permit hidden sales) can lead to fines up to €24,000. [factursystem.com]
- Note that these penalties can be applied per infraction, so multiple missing e-invoices could multiply fines. Additionally, the anti-fraud software law (Law 11/2021) imposes separate penalties: using software that is not certified (not Verifactu-compliant) to issue invoices could result in fines up to €50,000 for the business, and software providers can be fined €150,000 for each client they supplied non-compliant software to. This is to ensure businesses use approved billing systems that transmit data faithfully. [factursystem.com], [factursystem.com]
- During the initial rollout, some grace period or smaller sanctions might be considered by authorities (as happened regionally with TicketBAI), but formally these are the sanctions in law.
- Spain has defined penalties in Law 18/2022 for failures related to electronic invoicing: [factursystem.com]
- Pre-filled VAT Returns:
- State level: The Spanish Tax Agency (AEAT) is moving toward pre-filled VAT returns using electronic data. For businesses using the SII reporting system (see next section), the AEAT already provides a service called Pre303, which generates a draft VAT return based on the invoices the business has reported in real time. Initially launched in 2020 for SII users, by 2021 this service was extended to all taxpayers (with varying degrees of pre-filled data depending on what data the AEAT has). Thus, large companies and many others now receive an offer of a pre-completed Form 303 (the periodic VAT declaration) that they can review and submit. [bdo.global], [bdo.global] [bdo.global]
- With full B2B e-invoicing, the authorities will obtain even more detailed and immediate data for all taxpayers, which could allow pre-filled VAT returns for virtually everyone in the future. Although not explicitly stated in the law, one expected benefit of mandatory e-invoicing is that tax authorities can draft quarterly VAT returns automatically, reducing compliance burden. (Already, SII data is used to auto-fill certain fields and eliminate other filings.) [flick.network], [flick.network]
- Regional level: In Bizkaia (Basque Country), the Batuz system will provide pre-completed tax returns to taxpayers based on the digital invoices (TicketBAI) and ledgers they submit. This includes VAT and income tax returns. This is a pioneering approach locally and mirrors what the AEAT may eventually do nation-wide.
- Official Regulations and Resources:
- Law 18/2022 (27 September 2022) – Established the upcoming B2B e-invoicing obligation and its broad strokes. This is the primary law (often called Ley Crea y Crece). [ey.com]
- Draft Royal Decree on B2B E-Invoicing – (in progress) Defines technical specifics and implementation. A draft was published in June 2023 and updated in March 2025. Final approval expected by late 2024 or 2025. Enforcement countdown (1 year/2 years) starts from the approval of a Ministerial Order that will follow this decree. [avalara.com], [avalara.com] [ey.com], [ey.com]
- FACe System – The government’s e-invoicing portal for B2G transactions (since 2015). It uses FacturaE format. Website:
face.gob.es. [avalara.com] - AEAT “Veri*Factu” specifications – The tax agency’s technical standards for certified invoicing software (published via RD 1007/2023 on 6 Dec 2023). Ensures software can transmit required data and secure the records. [bdo.global], [bdo.global]
- Ministry of Economic Affairs and Digital Transformation – Leading the e-invoicing project, in coordination with the Ministry of Finance (for tax aspects). Their releases (e.g., the submission to the EU Commission in Feb 2024) give context that Spain is aligning with EU e-invoicing norms. [avalara.com]
- Relevant EU Law: Directive (EU) 2022/… (pending adoption) to allow mandatory e-invoicing by member states (as part of the ViDA package, it will amend the VAT Directive’s Article 232 by 2024, removing the buyer consent requirement) – this is why Spain awaits EU approval. Also, the EU standard EN 16931 governs the semantic content of e-invoices (which UBL and FacturaE adhere to). [bdo.global]
E-Reporting in Spain (Real-Time VAT Reporting – “SII”)
- System Overview & Timeline:
- Spain’s electronic VAT reporting system is the Suministro Inmediato de Información (SII), which translates to “Immediate Supply of Information”. It was implemented starting 1 July 2017 as an online, real-time VAT bookkeeping regime. The legal basis came from Royal Decree 596/2016. SII essentially requires frequent submission of invoice data to the tax authorities, replacing certain traditional VAT return obligations. [flick.network]
- Scope of SII: It is mandatory for specific taxpayer categories, primarily those who were already required to file monthly VAT returns. This includes: [flick.network]
- Large companies with annual turnover above €6,010,121.04 (approx €6 million). [flick.network]
- VAT groups (groups of companies filing a consolidated VAT return). [flick.network]
- Taxpayers in the REDEME (Monthly VAT Refund Registry) regime. [flick.network]
- Additionally, any other business can opt in voluntarily to SII (but if they do, they must stay in the system for at least the whole calendar year). [flick.network], [flick.network]
- SII currently applies to around 30–40 thousand companies in Spain (the large taxpayers and others mentioned), which account for the majority of domestic business turnover. It does not apply to most SMEs who file quarterly VAT returns, nor to self-employed individuals unless they choose to join.
- Geographical coverage: SII is used for VAT in mainland Spain and the Balearic Islands (i.e., VAT managed by AEAT). It does not apply in territories with separate tax systems: the Canary Islands (which have IGIC tax instead of VAT), the North African enclaves Ceuta and Melilla (with IPSI tax), or the Basque Country and Navarra (which have their own tax authorities). Businesses in those regions report under different systems (unless they also have to report to AEAT for some reason). [flick.network]
- Transactions and Data Reported:
- Under SII, companies must electronically report the details of virtually all their sales and purchase invoices. Instead of keeping VAT books only internally and reporting summary totals in a VAT return, the invoice-by-invoice data is sent to the Tax Agency in near real time. [flick.network], [flick.network]
- The data is structured into four electronic VAT ledgers:
- Sales Invoices (Issued invoices) ledger – each record includes invoice number, date, customer VAT number, amount, VAT breakdown, etc. [flick.network]
- Purchase Invoices (Received invoices) ledger – similar details for each invoice received from suppliers (including import documents). [flick.network]
- Intra-Community transactions ledger – details of goods shipped to or received from other EU countries (required for EC sales/purchase listings). [flick.network]
- Capital/Investment goods ledger – records of fixed assets and certain investments, needed for tracking VAT deduction adjustments over time. [flick.network]
- Essentially, if an invoice is issued, its key data must be reported; if an invoice is received, that data must be reported as well. Each record also indicates certain additional info: e.g. invoice type (credit note, simplified invoice, etc.), any special VAT scheme applied, descriptions, and reference numbers for specific transactions (like customs entry numbers for imports).
- Data format: All the above information is sent as XML submissions following the schema defined by AEAT. Companies either have their ERP/accounting systems integrated with AEAT’s web service APIs to transmit data automatically, or they use the AEAT online portal to manually key in data (the latter only feasible for very low volumes). A digital certificate is used to authenticate submissions. [flick.network]
- Deadlines for Submission:
- SII imposes tight deadlines – effectively real-time reporting within a few days:
- Sales (issued invoices): must be reported within 4 calendar days from the invoice date. (If a third party issues the invoice on your behalf, the deadline is 8 days.) Regardless, all sales for a month must be reported by the 16th of the following month at the very latest. [flick.network]
- Purchases (received invoices): must be reported within 4 calendar days from the date the invoice was recorded in your books (i.e., when you receive and book the invoice). Similarly, the 16th of the next month is an absolute cutoff for late-arriving purchase invoices. [flick.network]
- Intra-Community transactions: information (like dispatch or arrival of goods) must be submitted within 4 days from the dispatch or receipt date. This aligns with reporting those transactions around the time they occur, rather than waiting for monthly Intrastat or EC sales lists. [flick.network]
- Investment goods: these are reported not in real-time but in an annual summary, due by January 30 of the following year. [flick.network]
- Note: The “4 days” are counted excluding weekends and national holidays, effectively meaning 4 business days. For example, an invoice issued on Monday must typically be reported by Friday of the same week. [flick.network]
- These tight deadlines mean larger companies must have automated processes to capture invoice data and send it quickly. The near-real-time flow gives the tax authority visibility of transactions as they happen throughout the VAT period.
- SII imposes tight deadlines – effectively real-time reporting within a few days:
- Penalties for Non-Compliance (SII):
- Spain’s General Tax Law sets penalties for failures in bookkeeping or VAT reporting, and specific ones were outlined for SII to encourage compliance:
- Late reporting of invoices: A fine of 0.5% of the invoice amount for each invoice reported past the deadline. There is a minimum fine of €300 and a maximum of €6,000 per quarter (per VAT ledger). This means if a batch of invoices was delayed, the 0.5% each could add up, but the total for, say, all late sales invoices in Q1 cannot exceed €6,000. [flick.network], [flick.network] [flick.network]
- Errors or omissions: If data is incorrect or an invoice is omitted entirely, the fine is 1% of the invoice amount (or of the amount of the error). Minimum €150, max €6,000 per quarter. This covers providing wrong info that could affect tax (e.g. putting wrong VAT amount). [flick.network], [flick.network]
- Late reporting of certain other records: For intra-community or investment goods ledgers, a fixed penalty of €150 per record applies if those are late. [flick.network]
- Complete non-compliance: If a company required to use SII simply doesn’t submit anything, a penalty up to 1% of its annual turnover can be imposed (minimum €600). This is a severe penalty aimed at deterring outright refusal to comply. [flick.network]
- Importantly, if errors are corrected voluntarily before the tax authorities raise an issue, penalties can often be mitigated or avoided. The system encourages prompt correction (the AEAT sends immediate feedback on submissions, rejecting those with errors that must then be fixed). [flick.network], [flick.network]
- These fines mean SII compliance is taken seriously, but in practice once companies automate the process, the data submission becomes routine. Also, SII was introduced with some leniency in the first few months of 2017 to allow adaptation. By now, audits on SII data accuracy are part of normal VAT control.
- Spain’s General Tax Law sets penalties for failures in bookkeeping or VAT reporting, and specific ones were outlined for SII to encourage compliance:
- Benefits and Pre-Filled Returns:
- One benefit of SII for taxpayers is reduced ancillary filings. Businesses using SII are exempt from filing forms 347 (annual customer/supplier listing), 340 (detailed transaction listing), and 390 (annual VAT summary). These are redundant because the tax office already has the detailed data continuously. This simplifies year-end compliance. [flick.network]
- The AEAT also uses SII data to offer pre-populated VAT returns. Starting in 2020, the AEAT rolled out the “Pre303” service, which auto-drafts the periodic VAT return (Form 303) for SII users using the data they’ve reported. By 2021, Pre303 was extended to all taxpayers (with SII users getting the most complete drafts, since the agency has all their invoice data). Through Pre303, a company can log into the tax portal and see a proposed return with amounts already filled in from their SII (and other info like previous credits, etc.). The taxpayer just needs to confirm or adjust before submission. This is one of the first examples in the EU of pre-filled VAT returns thanks to digital reporting. [bdo.global], [bdo.global] [bdo.global]
- Faster detection of discrepancies is another advantage – since purchases and sales are reported by both sides, the tax authority can cross-match what one company claims as a sale vs. what the counterparty claims as a purchase, and quickly flag mismatches (helping to combat fraud).
- Companies in SII also often find that having cleaner, real-time data helps with internal controls and quicker VAT refunds (as the authority has up-to-date info when processing refunds).
- Official Resources:
- AEAT SII Portal: The Spanish Tax Agency’s website has a section for SII, including general information and FAQs and technical guidelines for the XML web service. (Site:
sede.agenciatributaria.gob.es -> Immediate Supply of Information). - Regulations: Royal Decree 596/2016 (which modified VAT regulations to introduce SII) and Order HFP/417/2017 (which implemented the technical details) are the key legal texts. Additionally, each year’s Budget Law and VAT law updates include any tweaks to SII (e.g., extending deadlines or including new fields).
- Guidance: The AEAT publishes BOE (official gazette) notices and has an online “SII Manual” that is updated periodically. These outline the data fields, error codes, and examples for submissions.
- Note: SII is essentially Spain’s national precursor to the EU’s upcoming Digital Reporting Requirements (DRR). The system may evolve further once the EU mandates real-time reporting for all businesses (see ViDA section below), but Spain is ahead of many countries due to SII’s early adoption.
- AEAT SII Portal: The Spanish Tax Agency’s website has a section for SII, including general information and FAQs and technical guidelines for the XML web service. (Site:
E-Transport in Spain (Electronic Transport Documents)
- Mandate & Background:
- Spain is digitizing the “control documents” required for road transport of goods. The key document is the Carta de Porte (consignment note) for road freight, which serves as a contract of carriage and must accompany the shipment. Traditionally this has been on paper. Spain’s forthcoming regulations will make the electronic consignment note (e-Carta de Porte or eCMR) mandatory, in line with EU-wide developments in freight transport digitalization.
- This change ties into the EU’s eFTI Regulation (EU 2020/1056), which obliges Member States’ authorities to accept electronic freight transport information by 2024-2026. The EU aims for all cross-border road transports to use the electronic CMR (Convention on the Contract for the International Carriage of Goods by Road) format by late 2026. Spain is going a step further by making electronic documents compulsory for domestic transport as well. [froet.es], [froet.es] [froet.es]
- Timeline in Spain:
- Initially, the Spanish government planned to include this in the new Sustainable Mobility Law. In fact, the Minister of Transport announced that the law would be approved by end of 2024, and that would trigger a countdown to mandatory e-Carta de Porte by January 2026. [froet.es]
- However, to expedite things, in mid-2025 the Ministry introduced a draft Royal Decree (as a modification of the transport regulations ROTT) specifically to enforce digital transport documents without waiting for the broader law. Public consultation for this decree ended 8 July 2025. The expectation is the decree will be approved by late 2025. [docuten.com], [docuten.com] [docuten.com] [diariodetr…sporte.com]
- A transition period of around 12 months is anticipated after approval. This likely means that by late 2026 or early 2027, it will become compulsory to use electronic format only for consignment notes in road transport. Industry sources predict a full switch to digital by 2026’s end, with 2027 being the point of no return for paper. (In other words, once 2026’s one-year moratorium is over, paper documents will no longer be legally valid for road freight in Spain.) [diariodetr…sporte.com] [diariodetr…sporte.com], [docuten.com]
- These dates align with the EU timeline: by December 2026 all European authorities must be ready to accept e-docs, and Spain aims to require all companies to use e-docs by roughly that time. [froet.es]
- Transactions in Scope:
- The requirement covers road transport of goods under Spain’s jurisdiction. Specifically: any transport that currently requires a “documento de control” (control document) as per Spanish law will have to use an electronic format. Under current rules, any commercial road shipment with a freight contract value over €150 must have a consignment note, so those will all need to be electronic. In practice, this includes most B2B freight movements by truck.
- Domestic transports: All intra-Spain road freight operations by transport companies (public transport of goods) are included. For example, if a carrier is moving goods for a client from Madrid to Barcelona, the consignment note must be digital. [docuten.com]
- International road transports: Spain is a signatory of the CMR Convention and its additional eCMR protocol. The mandate will ensure that international road shipments from Spain use the eCMR (the digital version of the CMR consignment note) instead of paper CMR. The law will require carriers to issue an electronic CMR for cross-border trips, and authorities will accept it.
- Other modes of transport (rail, sea, air) have their own documentation (like bill of lading, etc.) and are also subject to EU eFTI standards but their digitization might be addressed separately. The current focus is on road haulage, which is where a standardized e-document (eCMR) is already in place.
- Who is in Scope:
- Transport companies (carriers) and shippers (senders of goods) are both responsible for ensuring the existence of an electronic consignment note. Typically, the shipper is responsible for preparing the consignment note at shipment and the carrier must carry it. Under the new system, both parties will likely need to use certified digital platforms to create and sign these documents.
- Enforcement will be by transportation inspectors and traffic authorities (e.g., Guardia Civil on highways) who will check freight documents. They must be equipped to read the electronic document – likely via a mobile app or a national access portal where the document can be retrieved using a reference or scanning a QR code provided by the carrier.
- All sizes of business in the sector are included – even small trucking companies will have to comply, not just large logistics firms. The regulation might allow freelance truckers or very small operators some simplified method (like using a free government web portal to generate an e-document) to ensure no one is left behind.
- Data and Format (E-Transport):
- The electronic consignment note will contain the same information as the paper one: details of the shipper, carrier, and receiver; date and place of taking over the goods and delivery; description of goods, quantity, weight; transport charges; and any instructions or liability clauses. Nothing is being added or removed content-wise – it’s the format that changes from paper to structured digital data.
- Format & Platforms: Spain will implement a solution likely based on the international eCMR standard (for road transport) and in line with the EU eFTI framework. The eFTI regulation calls for certified platforms and a common data model. So the e-Carta de Porte might be an XML or JSON format document (or PDF with embedded data) that can be exchanged. The important thing is that it’s electronically generated and stored, not just a scanned paper.
- The draft regulation suggests eliminating the dual paper/electronic option and making electronic the only valid way to “communicate these data”. This implies a centralized or interconnected system: possibly a National Access Point (NAP) for transport data as required by the EU. Companies might upload each e-consignment note to this NAP or register it via an online service. [diariodetr…sporte.com]
- Verification: Each e-document will likely have a unique ID or QR code. An inspector could scan the QR code from a driver’s mobile device or a printed code, which would pull up the official record of the consignment note from the system. This ensures authenticity and that the data hasn’t been tampered with. [diariodetr…sporte.com]
- Submission / Due Dates:
- Unlike e-invoicing where data is pushed to tax authorities immediately, the e-transport document needs to be available during the transport. So the “deadline” in practice is that before the journey begins, the consignment note must be created in electronic form and effectively registered such that it can be accessed by authorities.
- In other words, the moment a truck is on the road with goods, it should already have its digital paperwork completed. There isn’t a periodic submission; it’s per shipment.
- There may be a system in place where the data is transmitted to a government system at the time of issuance (for oversight or simply to facilitate retrieval). If Spain sets up a platform, shippers might have to upload the e-note to that platform ideally immediately when goods are dispatched.
- For practical purposes, companies will integrate this into their logistics process – e.g. generating the eCMR when loading the truck, and the data being instantly shared.
- Penalties for Non-Compliance (E-Transport):
- In the current law, if a carrier does not carry a proper consignment note for a required shipment, it’s considered a violation of transport regulations. Typically, fines in Spain for missing or improper transport documents can range from a few hundred up to a few thousand euros depending on severity (classified as minor or serious infringement under the Land Transport Regulations). For example, not having the mandatory documentation might be a serious infringement which could be a fine on the order of €401 up to €2,000 (this range is an example, exact amounts are set in transport law).
- Under the new regime, those provisions will adapt to the electronic format: if a company fails to use the electronic document when required (e.g. continues to use paper or has nothing at all), it will face the same penalties as failing to carry a consignment note today. In addition, there could be penalties if the data in the electronic note is intentionally falsified.
- Another implication: if a carrier cannot produce the e-document for inspection (because they didn’t generate it, or system issues), the truck could be impounded or delayed until compliance is achieved, just as it would if paper documents were missing. So compliance is operationally critical.
- The government is likely to give a grace period once it becomes mandatory (the “moratoria” mentioned) so that enforcement actions are not draconian in the first months of the switch. But by 2027, companies should expect full enforcement.
- Official Resources & References:
- Ley de Movilidad Sostenible (Sustainable Mobility Law) – pending law that contains the legislative basis for mandatory e-transport documents (expected late 2024). [froet.es]
- Proyecto de Real Decreto (June 2025) – draft regulation amending ROTT (Transport Regulations) to mandate digital control documents, announced by the Transport Ministry. This will likely be finalized as a Royal Decree in late 2025. [docuten.com]
- EU Regulation 2020/1056 (eFTI): Effective Aug 2024, it sets up the framework for electronic freight transport info in the EU. Key dates from EU: by Aug 2025, Member States should have designated platforms/NAPs; by Dec 2025, begin accepting data; by Dec 2026, all authorities must accept e-docs. Spain’s national regulations are aligning with this timeline. [froet.es]
- Ministry of Transport (MITMA) releases: Statements by officials (e.g., Oscar Puente, Sept 2024) confirming Spain’s timeline, and explanatory notes on the benefits of the digital transition (efficiency, traceability, reduced admin). These can be found on the MITMA website or related transport industry bulletins. [froet.es] [docuten.com]
- For operational details, once implemented, the transport authority will publish guides for carriers on how to use the new system (likely through the Spanish road transport directorate).
Regional Differences within Spain (Basque Country & Navarra)
Spain’s regions of País Vasco (Basque Country) and Comunidad Foral de Navarra have autonomous tax systems and have introduced their own e-invoicing and e-reporting requirements, which differ somewhat from the state system.
Spain’s regions of País Vasco (Basque Country) and Comunidad Foral de Navarra have autonomous tax systems and have introduced their own e-invoicing and e-reporting requirements, which differ somewhat from the state system.
- Basque Country – TicketBAI and Batuz:
- TicketBAI (TBAI): This is a mandatory e-invoicing and instantaneous reporting system rolled out by the three Basque provincial tax authorities (Diputaciones Forales of Álava, Bizkaia, and Gipuzkoa). It aims to combat tax evasion by ensuring every invoice issued by a business is digitally reported to the tax authorities.
- How it works: Businesses in the Basque Country must use certified billing software that is TicketBAI-compliant. Each invoice generated has an embedded TBAI code and a QR code, and the software automatically sends the invoice data (XML file with invoice details and a cryptographic hash) to the provincial tax authority’s server at the moment of issuance. This way, the tax office receives transaction data in real time, similar to SII but at the point of invoice creation. [bdo.global], [bdo.global]
- Timeline:
- Gipuzkoa was first: TicketBAI became mandatory for most taxpayers during 2022, with a phased schedule by sectors (starting with large companies and certain professionals) and full coverage by end of 2022.
- Álava (Araba) closely followed and also had it mandatory by end of 2022 for virtually all businesses.
- Bizkaia took a slightly different approach by integrating TicketBAI into a larger program called Batuz. Batuz includes TicketBAI + additional ledger reporting to Bizkaia’s Hacienda. Bizkaia made TicketBAI mandatory from January 2024 for all businesses (after a voluntary period in 2022–2023). However, during 2024 Bizkaia offered a grace period with no fines for those who show they are trying to comply. By 2025, compliance is expected to be strict. All three provinces now either have or are finishing the rollout of compulsory TicketBAI for 100% of companies and self-employed under their jurisdiction.
- Scope: TicketBAI in Basque Country applies to all transactions (B2B, B2C, etc.) by taxpayers under the Basque income tax/VAT regimes. If a business pays its taxes to the Basque Hacienda, it must use TicketBAI for all its invoices, whether the customer is another business, a consumer, or a government entity. It’s not limited to certain sizes or sectors (only the rollout schedule was staged).
- Data & Format: The TicketBAI XML includes detailed invoice data (similar to an invoice itself) plus additional fields like a unique TBAI identifier and digital signature computed by the software. The QR code on each printed or PDF invoice allows the client or tax inspector to scan and verify the invoice’s authenticity on the tax authority’s system. [bdo.global]
- Use of data: The Basque tax authorities use TicketBAI data to cross-check declared income. Bizkaia’s Batuz system goes further by using TicketBAI inputs to pre-fill tax returns (VAT, corporate tax, income tax) for the taxpayer – a service that will start when Batuz is fully live.
- Penalties: The Basque norms set hefty penalties to ensure compliance. For example, in Gipuzkoa and Álava, not adopting TicketBAI on time could result in a fine of 20% of the prior year’s turnover (minimum €20,000). Bizkaia set fines of €20,000 for failure to comply, with incremental penalties per each subsequent infringement. These were intentionally high to discourage any idea of risking non-compliance. However, tax credits (of up to 30% of software costs) were offered as incentives for early adopters, and initial enforcement was somewhat lenient. By now, though, businesses in those areas must be compliant or face sanctions.
- Interaction with state system: If a Basque business is in SII (say a large company in Bilbao), it actually must do both SII and TicketBAI reporting. However, the state AEAT and the Basque Haciendas are working on data-sharing so that duplication is minimized. Still, formally, those businesses have to submit invoice data to both systems (one to AEAT for VAT SII, and one to their Diputación via TicketBAI). The new national VeriFactu system is separate; Basque taxpayers under TicketBAI are generally not subject to the national e-invoicing mandate as long as they don’t fall under state tax authority.
- Navarra – Digital Invoicing System:
- Navarra, like the Basque provinces, has an autonomous tax authority. It has announced a plan for its own version of TicketBAI. Often referred to as “TicketBAI Navarra” or the Navarrese Electronic Invoice System, it will similarly require all businesses under Navarrese tax regime to issue invoices with secure, traceable software.
- Timeline: Navarra’s government approved in 2023 the roadmap to implement mandatory e-invoicing. A voluntary phase started, and the intention is to mandate it by 2025 or 2026 for all sectors. The exact dates are being set by local law; the latest information suggests a target of 2025 for large companies and a bit later for smaller ones, but subject to confirmation. By 2026, Navarra aims to have every taxpayer issuing only electronic invoices. (Navarra needed to legislate this independently, and coordinate with the central government since many businesses operate across regions.) [docuten.com]
- Technical aspects: Expected to be very similar to TicketBAI – unique invoice files with QR codes, immediate communication to Navarrese Hacienda. It may even use the same software certifications as TicketBAI (so that software developers don’t have to reinvent the wheel for Navarra).
- Penalties and incentives: Navarra will likely mirror the Basque approach: strong penalties for non-compliance, possibly coupled with transitional incentives (like tax deductions for software costs). The goal is to eliminate the possibility of hidden sales by requiring every sale to be logged with the tax office in real time.
- Until Navarre’s system is in force, businesses in Navarra continue with current requirements (which could include SII if they are in REDEME, etc., but not TicketBAI yet).
- Other Regions:
- The Canary Islands (which have their IGIC tax) have an electronic invoice and ledger reporting system called DIVA IGIC (implemented around 2019) for certain transactions, but it’s not as extensive as SII. They may consider expanding digital reporting as well, but it is separate from the mainland VAT system.
- Summary: Regional mandates like TicketBAI are additional layers of requirement but only apply to those under those jurisdictions. For companies operating nationally, the upcoming state e-invoicing (VeriFactu) and SII are the main ones to follow, but those in Basque/Navarra have to comply with local rules until perhaps a future harmonization occurs.
Spain and EU “ViDA” (VAT in the Digital Age) Considerations
- EU Digital Reporting Requirements (DRR): In March 2025, the EU formally adopted parts of the ViDA reforms, which will require all member states to move toward mandatory e-invoicing and digital VAT reporting in the coming years. Key elements include: by 2028, EU cross-border B2B transactions must be reported in real-time via e-invoices, and by 2030 domestic e-invoicing will become the norm across the EU. [bdo.global], [bdo.global]
- Spain’s alignment: Spain is ahead in many respects thanks to SII and its planned B2B mandate. Notably, Spain’s 2022 law anticipated the ViDA changes by making e-invoicing mandatory (which under old EU rules needed special permission). The EU is amending its laws to explicitly allow such mandates, so Spain’s rollout for 2027/28 is timed well.
- Intra-EU reporting: Currently, Spain uses the 349 form for EU sales listings. Under ViDA, that will be replaced by real-time reporting of intra-EU invoices (likely via the same system used for domestic). Spain will adapt SII or the new e-invoicing platform to comply with this by 2028. Given SII already captures a lot of data, Spain may just have to tweak it to send cross-border info to the new EU central database that will be set up.
- E-invoice formats: The ViDA proposals mandate a common e-invoice standard (EN16931) for cross-border exchanges. Spain’s adoption of UBL for its public platform and allowing CII is in line with this, since both UBL and CII are compliant syntaxes under EN16931. So Spanish businesses using these formats will be producing EU-standard invoices, facilitating interoperability. [ey.com]
- End of buyer consent: As noted, the EU is removing the requirement for buyer consent to receive e-invoices (Article 232 VAT Directive) by 2024. Spain was waiting for this change to fully enforce B2B e-invoicing. Once removed, Spain can enforce e-invoicing without legal hurdle. In effect, ViDA clears the way for Spain’s mandate to be legally solid. [bdo.global]
- Pre-Filled VAT Returns: A goal of ViDA is for tax authorities to use the granular data to offer pre-filled returns or even move to more transaction-based tax assessment. Spain’s Pre303 and Batuz are early examples. Spain will likely continue expanding the pre-filled approach, and with all invoices reported, the VAT return might eventually become just a confirmation exercise for businesses.
- One-Stop Shop & Platform Economy (other ViDA elements): While not asked, it’s worth noting Spain will also implement other parts of ViDA (like single VAT registration and new rules for platforms). But specifically for e-invoicing and reporting, Spain is essentially on track to meet the EU deadlines.
- Conclusion: Spain is actively modernizing VAT administration through e-invoicing, e-reporting, and now e-transport requirements. These changes involve:
- Mandating electronic invoices for B2B transactions, with phased implementation by ~2027, leveraging standardized formats and real-time transmission. [ey.com], [rtcsuite.com]
- Continuous transaction reporting (via SII) already in place for large taxpayers, soon to be complemented by full e-invoice data for all businesses, giving tax authorities timely information on all sales and purchases. [flick.network], [flick.network]
- Digital transport documents to streamline and secure the logistics chain, fully enforced by 2026–27. [diariodetr…sporte.com]
- Regional innovations like TicketBAI show the path to comprehensive e-compliance, and the state is following with its own system (VeriFactu) to ensure nationwide coverage. [bdo.global], [bdo.global]
- Preparation for EU reforms, meaning Spanish regulations are being designed to dovetail with the upcoming EU VAT reporting regime (Spain will be ready when intra-EU e-invoicing becomes obligatory under ViDA). [bdo.global], [ey.com]
Businesses operating in Spain should prepare early: adopt compliant e-invoicing software, adjust accounting processes to meet short reporting deadlines, and train staff on new systems. Official info can be found on the AEAT’s website and in the text of Law 18/2022, draft regulations, and EU documents cited above. Spain’s journey toward a fully digital tax environment is well underway, with more changes to come as the regulations are finalized. [rtcsuite.com], [bdo.global]
Sources: Recent tax news and official releases were used for the above information, including: Avalara (Jul 2025) updates on Spain’s e-invoicing timeline, EY Global Tax Alerts on the draft e-invoicing regulation, RTC Suite news on the 2024 postponement of the mandate, BDO insights on Spain’s e-invoicing and ViDA alignment (Nov 2024), Spanish consultancy articles on e-invoicing penalties, the Spanish Tax Agency’s SII guidelines, and transport industry publications on the eCMR implementation timeline. These sources and the Spanish laws (Law 11/2021, Law 18/2022, Royal Decrees, etc.) provide the basis for the summarized content. [avalara.com], [avalara.com] [ey.com], [ey.com] [rtcsuite.com] [bdo.global], [bdo.global] [factursystem.com] [flick.network], [flick.network] [froet.es], [diariodetr…sporte.com]
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
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