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Electronic invoice: obligations for freelancers and SMEs in Spain

Electronic invoicing is becoming mandatory in Spain. This guide explains who it affects, from when, the approved formats and how to prepare your business.

What electronic invoicing is and why it is becoming mandatory

Electronic invoicing (factura electrónica) is the digital exchange of invoice data in a structured, machine-readable format between suppliers and clients. Unlike a PDF invoice sent by email (which is not considered electronic invoicing), true electronic invoices use standardised formats (XML-based) that can be automatically processed by accounting software and government systems. The Spanish government is implementing electronic invoicing obligations as part of the Crea y Crece law (Law 18/2022) to reduce tax fraud, improve administrative efficiency and accelerate business payment times.

The Crea y Crece law establishes that electronic invoicing will become mandatory for business-to-business (B2B) transactions. The rollout is phased: large companies and public entities were first, followed by SMEs and autónomos (self-employed) in subsequent phases. For transactions with public administrations in Spain, electronic invoicing via the FACe platform has been mandatory for some years. The new obligation extends this to all B2B commercial transactions.

Who is affected and from when

Under the Crea y Crece law implementation, all entrepreneurs and businesses in Spain who carry out transactions with other businesses or professionals will be required to issue electronic invoices. This includes autónomos who invoice other businesses (not end consumers), SMEs of all sizes, and larger companies who must also be able to receive and process electronic invoices. Consumer-to-consumer and business-to-consumer (B2C) transactions are initially excluded.

The implementation timeline has been subject to delays and regulatory development. As of the time of writing, businesses should monitor official announcements from the Agencia Tributaria and the Ministry of Economy for confirmed implementation dates. The technical regulations (reglamento de facturación electrónica) define the specific requirements, and software providers are continuously updating their solutions. Check with your gestoría or accountant for the most current requirements applicable to your business.

Approved formats for electronic invoices in Spain

The Spanish regulations for private sector electronic invoicing require specific structured formats. The main approved formats are: Facturae (the native Spanish XML format required for invoicing public administrations), UBL (Universal Business Language, a widely used international XML standard), and CII (Cross Industry Invoice, the UN/CEFACT standard also used in the European EN16931 norm). Your invoicing software must be able to generate invoices in these formats, not just PDF.

The regulations also require digital signatures and timestamps to ensure the authenticity and integrity of invoices, a record-keeping requirement (invoices must be stored and accessible for the legally required period), and a system that allows the recipient to verify the status of invoices. These requirements go beyond simply sending a file — they require a proper electronic invoicing solution.

Software and tools for electronic invoicing

For autónomos and small businesses, the main software options for compliant electronic invoicing in Spain include: FacturaDirecta, Holded, Billin, Quipu, and ContaPlus. Most major accounting and ERP systems used by SMEs (Sage, SAP, Oracle) are already updating to support the required formats. The government also provides free tools via the Agencia Tributaria for those who cannot afford dedicated software.

When evaluating electronic invoicing software, key criteria include: compatibility with required Spanish formats (Facturae, UBL, CII), integration with your existing accounting system, ease of use for daily invoicing workflows, ability to send and receive electronic invoices, digital signature capability, and certified archiving. Many solutions offer monthly subscriptions starting from around €10-15 per month for basic plans.

How to prepare your business for the change

The practical steps to prepare: 1) Identify which of your clients are businesses (and will need to receive electronic invoices from you) versus end consumers. 2) Check whether your current invoicing software supports or will support the required formats — contact your software provider. 3) If you need new software, evaluate 2-3 options and select one before the mandatory implementation date. 4) Test the system with a few clients before the deadline. 5) Ensure your clients know they will start receiving electronic invoices and have software capable of processing them.

The transition is also an opportunity to modernise your overall invoicing and accounting processes. Electronic invoicing integrates naturally with cloud accounting software, automatic bank reconciliation and digital expense management. Businesses that adopt it proactively often discover efficiency gains beyond mere compliance — faster payment tracking, automated reminders and integrated VAT reporting.

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