Background

Since July 2017, quasi real time reporting through the SII ( Suministro Inmediato de Información) has been mandatory for taxpayers that are enrolled in the automatic refund mechanism with a turnover of more than EUR 6,010,121.06, and for VAT groups, for any type of transaction.

As a separate requirement, the three Basque provinces ( Álava, Vizcaya and Guipúzcoa) introduced a real time reporting system called TicketBAI. TicketBAI is only applicable in these three provinces. Since 2022, TicketBAI has been live. The implementation timeline differs among different regions.

B2G e-invoicing is mandatory for transactions with a value above EUR 5.000 in Spain and FACe platform is used for this type of transactions. However, there is no e-invoicing requirement for B2B invoices at the moment. That being said, according to the "Create and Grow" law, taxpayers should be required to issue e-invoices for each transaction. The timelines to comply with the upcoming B2B e-invoicing mandate have not been determined as it depends on the date of approval of the implementing regulations:

1. Companies with an annual turnover exceeding €8m: one year after the date of the approval of the implementing regulation
2. All other companies and professionals: two years after the date of the approval of the implementing regulation

The most recent update in Spain is the introduction of mandatory use of certified billing software from July 1, 2025, as per Royal Decree 1007/2023. The software must issue invoices and generate a record in a structured XML format with certain transactional data, which will need to be transmitted to the Spanish Tax Authority. Taxpayers subject to the SII are not under scope. The certified billing software requirement will coexist with the upcoming mandatory B2B e-invoicing mandate. Learn more about certified billing software requirements in Spain.

What Types of Businesses Does SII Apply to?

• Taxpayers with a turnover of more than EUR 6,010,121.06
• Taxpayers enrolled in the automatic refund mechanism (REDEME)
• VAT groups

Governmental Body Responsible for SII in Spain

Invoices received and issued should be reported via the SII (”Immediate Supply of Information”). SII is an information system created by the Agencia Tributaria, the Spanish tax authority. The report is made through its portal.

Penalties for Not Adhering to Spain’s E-invoice Mandates

A fine of up to 0.5% of the total transaction value for each invoice reported late. The minimum fine is EUR 300, and the maximum is EUR 6,000 per quarter. Secondly, there will be a fine of between EUR 150 and EUR 6,000 for failure to carry out proper bookkeeping.

What does the e-invoicing process in Spain look like?

1. The taxpayer should obtain an authorized electronic certificate and have a user in the Agencia Tributaria portal.
2. The taxpayer should establish a connection between its ERP and the SII information system.
3. The taxpayer should report details of invoices issued and received within the deadlines.

Is SAF-T Needed in Spain?

SAF-T has not been introduced in Spain.

E-Invoicing & Global Tax Automation with Fonoa

One way to comply with Digital Reporting Requirements in Spain is to use a provider like Fonoa.

With Fonoa you can:

• Have one integration for your global needs, including Spain
• Save time and money by automatically cleaning your data to minimize errors and manual work
• Utilize our validation mechanisms to ensure reporting accuracy, data completeness, full control, and compliance
• Rest assured that transactions are successfully reported or queued for internal investigation with our retry mechanisms
• Get full visibility with our dashboards by filtering criteria, analyzing granular transaction data, and quickly importing /exporting information