Electronic invoicing and e-Reporting in Spain

Mandatory Use

Since 2015, electronic invoicing has been mandatory for transactions with Public Administrations in Spain. This obligation was established under Law 25/2013 and requires that all invoices issued to the public sector be submitted electronically and digitally signed.

As of 2018, the regulation extended this requirement to subcontractors and contractors working with the Administration, who must also invoice electronically when the invoice amount exceeds €5,000.

Invoice format

The mandatory electronic format for invoices submitted to Public Administrations is Facturae.

Facturae is a structured XML format defined by the Spanish government that contains all the required invoice fields and enables automated processing. Suppliers must generate their invoices in this format for them to be accepted by the public sector. The general invoice reception platform for Public Administrations is FACe, which acts as a common entry point for Facturae invoices sent to any public body.

Electronic signatura

All B2G invoices must include an advanced electronic signature (XAdES) embedded in the Facturae XML itself.

This ensures the authenticity of the origin and the integrity of the invoice content. In Spain, the law requires that electronic invoices to the Administration be digitally signed; therefore, the use of a digital certificate for signing is mandatory. The XAdES (XML Advanced Electronic Signature) format complies with the European standard and is the one used in Facturae.

Archiving

Issuers of B2G invoices must retain electronic invoices for a minimum legal period of 5 years. During that time, invoices must be kept in a secure, integral, and accessible electronic format for potential inspections or audits.

Invoice Workflow

1. Issuance and validation: Extraction of supplier ERP data and transformation into the XML–Facturae schema defined by the Spanish Tax Agency, with the application of validation mechanisms to ensure all required information is included.
2. Electronic signature: Application of the legally established electronic signature mechanisms, which guarantee the integrity and authenticity of the electronic invoice. This is an advanced electronic signature based on a digital certificate (XAdES).
3. Submission to PGEFe: Once validated, the invoice is sent to the PGEFe (General Entry Point for Electronic Invoices) that public bodies have in place, or to FACe in the case of bodies affiliated with the General Entry Point of the State Administration.
4. Electronic Archiving: Archiving of the original XML–Facturae invoice in a secure and accessible electronic environment for the 5 years required under Spanish law. 

What is the SII and when did it come into effect?

The SII is an online system developed by the AEAT for the electronic management of VAT ledgers. It requires businesses to digitally submit invoice records via the AEAT’s electronic headquarters within very short timeframes. The system has been in effect since July 1, 2017.

Who is affected by the SII AEAT – Immediate Supply of Information in Spain?

The SII is mandatory for specific groups of taxpayers defined by the Spanish Tax Agency:

• Large companies: those with an annual turnover exceeding €6,010,121.04, representing a significant share of VAT collected in Spain.
• VAT groups: entities that file the tax on a consolidated basis and must electronically submit records of all their transactions.
• Taxpayers enrolled in the REDEME regime (Monthly VAT Refund Scheme): companies that request monthly VAT refunds, requiring continuous and detailed monitoring of their transactions.

In addition to these groups, the regulation also allows any company or professional to voluntarily opt in to the SII.

What is VeriFactu?

The VeriFactu modality involves the immediate, secure, and automatic submission of billing records to the AEAT electronic headquarters, preventing any subsequent alteration. This ensures system reliability and transparency while enabling effective tax supervision.

It is important to note that a SIF (Billing Software System) refers to any program or platform that implements the regulation’s requirements to guarantee the security of billing records. It can operate in either basic or advanced mode, with VeriFactu being one of the advanced modalities.

Who is affected by the VeriFactu regulation and what is the implementation timeline?

The VeriFactu regulation applies to the vast majority of companies and professionals in Spain, with the only exception being those already required to submit their VAT ledgers through the Immediate Supply of Information (SII).

Following the publication of Royal Decree 254/2025, a phased rollout schedule has been established to facilitate adaptation:

• Corporate Income Tax taxpayers must have their billing systems adapted and compliant by January 1, 2027.
• Self-employed workers and the rest of the obligated taxpayers have an additional period and must comply with the regulation starting July 1, 2027.

What is TicketBAI and why was it created?

TicketBAI is a joint system implemented by the Provincial Tax Authorities of Álava, Bizkaia, and Gipuzkoa together with the Basque Government. Its purpose is to electronically control all invoices and receipts generated, ensuring authenticity and preventing manipulation or exclusion from the tax circuit.

Each invoice or receipt must be issued using certified software (officially registered) that incorporates a TBAI identification code and a QR code and this automatically sent to the corresponding Provincial Tax Authority.

The system is especially focused on transactions with final consumers (particularly cash payments), enabling tighter control over actual revenues.

What is LROE in the Batuz system (Bizkaia)?

In Bizkaia, the rollout of TicketBAI is complemented by the LROE (Economic Transactions Record Book) within the Batuz system. This means that, in addition to issuing electronic invoices meeting TicketBAI requirements, taxpayers must also submit a structured and comprehensive record of all their economic transactions.

This electronic ledger is filed through Form 140 (for self-employed professionals) and Form 240 (for corporations), allowing the Provincial Tax Authority to have detailed and up-to-date information on each taxpayer’s activity.  Thanks to this, the LROE facilitates the automatic preparation of draft VAT, Corporate Income Tax, and Personal Income Tax returns, reducing administrative burdens and simplifying tax compliance.