04.06.23

Public consultation for B2B e-invoicing and technical specifications postponement

Developments with respect to B2B e-invoicing in Spain are taking pace as the Spanish government signals their intent to collate public sentiments around e-invoicing. B2B e-invoicing in Spain is expected to be mandated during 2024, although exact timelines are yet to be confirmed. You can read more about Spain’s B2B e-invoicing mandate, and the background to the associated Crea y Crece law, here.  

The Ministry of Economic Affairs and Digital Transformation in Spain this month launched a public consultation on the proposed B2B e-invoicing mandate. 

The scope of the questions contained within the public consultation are numerous and broad in nature, encompassing the following topics:  

• E-invoicing application scope, including exemptions 
• Whether the framework covers a public or private realm 
• Format interoperability  
• Platform interconnections  
• Invoice statuses 
• Submission to tax authorities  
• Considerations relating to small companies and the self-employed, and potential connection for low-volume issuers.  

The breadth of questions (specifically, 32 questions) suggests the government is keen to derive public sentiment that will ultimately shape the e-invoicing solution that Spain will adopt.    

The public consultation ended on 22 March 2023, and can be accessed via the following link: 

https://portal.mineco.gob.es/es-es/ministerio/participacionpublica/consultapublica/Paginas/Consulta_publica_creacion_crecimiento_empresas_factura_electronica_entre_empresas_y_profesional.aspx  

Further details on the scope of the public consultation (in Spanish) is available via the following link: https://portal.mineco.gob.es/RecursosArticulo/mineco/ministerio/participacion_publica/consulta/ficheros/230302_Consulta_publica_creacion_crecimiento_empresas_factura_electronica_entre_empresas_y_profesional.pdf 

The Crea y Crece Law was passed on September 2022, resulting in a 6-month timeframe for the Spanish tax authorities to produce technical requirements relating to their e-invoicing solution. However, it has now been confirmed that the technical specifications, due this month according to this timeline, have now been postponed. This is perhaps unsurprising, given that the public consultation only just concluded this month. 

While we can expect Spain’s technical specifications to now be published later in the year, Tungsten looks forward to analysing these specifications with a view to determine how we can best serve our Spanish customers with the demands imposed by the mandate.