What does the future hold for e-invoicing in Spain?

This new law brings with it changes that affect the invoicing process of companies and self-employed workers. It will mainly establish the obligation to bill electronically among all companies.

After reading Article 12, we have several questions as to what the requirements of the new billing regulation will be, and especially on how to implement it.

To answer these questions, we have to wait for the full publication of this Law, which is expected in late Q1/2023. The details of what technical process to use will be provided at that time. Another significant milestone is the start of the mandatory requirement for electronic invoicing in Spain, which will be in late Q1/2024, though only for companies that invoice more than 8 million. In 2025, this obligation will be extended to all other companies.

Reason for the change

The driving force behind this new Law is the Ministry of Finance's desire for efficiency and transparency. Everyone knows that digitising the invoicing process improves efficiency, adding value to every sector of the economy. Secondly, it seeks greater transparency in enforcing the Late Payments Law, which aims to combat defaults and prevent abuses when setting payment deadlines. Although this Law has been in force for more than 10 years, it is not generally complied with, which is why the government is looking for ways to enforce it.

Thus, the implementation of this new regulation will make it possible for businesses to exchange invoices electronically, advertise payment periods, and offer traceability and transparency to enforce the current Late Payments Law.

Points we can already take into account

Spain already has an electronic process for invoicing government agencies. This process relies on the FacturaE 3.2.x invoice format, and the delivery of online invoices at a general point of entry called FACE.

One might think that the new invoicing process for the private sector will be same or similar, but the government has revealed that it will not use this model.

In addition, the invoice in PDF format is currently accepted as an original invoice, and therefore, since it is a "digital" document, it might be considered as an electronic invoice; however, another point that has been revealed is that the electronic invoice will have to be a structured electronic document, meaning an electronic document similar to paper will not be accepted as an electronic invoice.

Many countries, both within and outside the European Union, already have electronic invoicing, and many others are in the process of implementing it. There are several possible deployment models; in the case of Spain, the government will rely on the synergy of the current network of electronic document exchange providers. Thus, by combining all the existing infrastructure, the goal is to provide the interoperability needed to exchange invoices B2B in Spain.

The main reason for this decision is to be able to keep the current electronic invoicing in the private sector that currently operates through these networks, such as in the automotive and distribution sectors, among others. This leads us to believe that, as is already the case, with the new Law there will be more than one electronic invoice format.

How we should prepare for electronic invoicing

There are many things still to be ironed out, and we have to wait for the text of the new law to be released in late Q1/2023. This regulation will specify how to share information on the status of the invoice, as well as: who must decide the identification of the recipients, how the annexes will be processed and who will be responsible for mapping the invoice format between the issuer and the recipient, among many other points.

What we can be sure of is that we will be required to use a structured format, and we can set up our ERP system to issue a recognised format and that can be easily mapped to other formats on the market.

One point that's been overlooked with the change in the new Law is the receipt of invoices, which offers a real chance to improve productivity.

The requirement for most companies to invoice using structured documents provides a simple opportunity to automate the invoice reception process.

To do this, we have to prepare our computer systems to automatically process and record electronic invoices, speed up the processing of incidents involving invoices, and digitise the internal approval process in order to streamline the intake process and cut red tape.

SEIDOR offers the e-Invoicing for SAP by SEIDOR solution, which has everything you need to comply with good practices and current regulations. We also plan to include the specifications needed to comply with future laws in a simple and secure way directly from your SAP system.

In conclusion, we are facing a sea change in how B2B invoicing is done, which will affect the majority of the companies we work with in the medium term, which is why we have to pay attention to any new information that comes out this year and plan the changes needed to comply with the implementation timeline.