Digital reporting requirements

B2G: Centralized (FACTURAE via FACE platform)

B2B: Post-audit (future VeriFactu= real-time reporting once in force & Ley Crea y Crece)

Basque Country: TicketBAI (CTC – real-time reporting to Foral Tax Authorities, not clearance)

Obligatory

B2G:

  • Issuance: Mandatory for suppliers of goods and services to Public Administrations.
  • Reception: Mandatory for public administrations and in relations between contractors and subcontractors when the value is greater than 5,000 euros.

B2B:

  • Issuance and Reception: Voluntary. (until Ley Crea y Crece mandate enters into force).

B2C:

  • Issuance and Reception: Voluntary, but permitted.

Authority

AEAT – Agencia Tributaria (State Tax Agency)
Foral Treasuries in Basque Country (TicketBAI).

Platform

Reporting: SII – Suministro inmediato de información.

SILICIE – Suministro Inmediato de Libros Contables de Impuestos Especiales

Basque Country:  TicketBAI (CTC real-time reporting) + LROE (economic operations ledger, required in some territories).

Format

B2G: FACTURAE XML via FACE
B2B: Future format: pending Ministerial Order (expected based on EN16931/UBL/Factur-X models).

Storage time

6 years

Reporting and processes

SII: Mandatory for companies >6M €, VAT groups and REDEME.

SILICIE: Mandatory for excise operators.

VeriFactu: Will require certified invoicing software that either reports invoice records in real time to AEAT or stores them locally with integrity guarantees.

Upcoming legislative changes

Spain will implement mandatory electronic invoicing in all B2B relationships between companies and the self-employed.

Although it has not yet entered into force, it will be implemented in phases that will apply once the Ministerial Technical Order is published, which will trigger the countdown.

Companies with annual revenue over €8 million:

  • Mandatory to issue and receive e-invoices and report invoice status: 12 months after the publication of the Technical Ministerial Order.
  • For the first year, electronic invoices must be accompanied by a PDF version, unless the recipient waives this.

Companies with annual revenue under €8 million:

  • Mandatory to issue and receive e-invoices: 24 months after the Technical Order is published.
  • Mandatory to report invoice status: 36 months after the same date.

The system will be decentralized and will require all companies to use interconnected certified suppliers, which will send invoices both to the recipient and to a central registry. In addition, the recipient’s suppliers must report on the status of the invoice (accepted, paid or rejected).

Links of Interest and documents

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