Spain Postpones Mandatory B2B E-Invoicing to 2027: New Timeline and Phases

Not too long after receiving approval on the Draft Royal Decree on the so-called Creation and Growth (Ley Crea y Crece) from the European Commission, a significant milestone, the Spanish government announced that it would postpone the implementation of mandatory  B2B e-invoices.

This may relieve taxpayers, especially those unprepared for these changes, but the Spanish government remains dedicated to fully implementing the B2B e-invoicing rules.

Postponement Reasons and New Timeline

It was initially expected that the implementation process of mandatory B2B e-invoicing would commence in mid-2025 or early 2026 at the latest. However, the decision to postpone was made due to the slow development of the technical specifications needed for the e-invoicing system to work appropriately and efficiently. 

Although the implementation process is delayed, this will have only a slight effect on the implementation timeline, whereas the Spanish government stated that it will remain within the framework of the original plan.

According to the new timeline, the implementation process will be completed in two phases. Phase one should start in 2027, 12 months after the final regulation is published in the Official Gazette. Large taxpayers with annual turnover above EUR 8 million will be first subject to B2B mandatory e-invoicing. 

In 2028, 24 months after the final regulation is published in the Official Gazette, all other taxpayers will have to follow B2B e-invoicing rules.

Conclusion

It remains to be seen in what timeframe Spanish governing bodies will develop technical specifications for implementing mandatory B2B e-invoicing and when the final version of the regulation will be published in the Official Gazette.

These are the two main next steps toward full implementation of B2B e-invoicing rules, whereas the publication date is specifically crucial for taxpayers. Based on the publication date, the implementation deadline starts for large taxpayers and others to adjust their systems and operations under the new rules.

Source: SNI, Taxopolis, VATabout