Spain B2B e-invoicing: adopted under Crea y Crece, but not yet in force

Ley Crea y Crece (Law 18/2022) is the Spanish law that mandates B2B e-invoicing. It requires all businesses to send and receive electronic invoices, phased by company size starting with large companies (>€8M revenue).

Facturae is Spain's national e-invoicing format (XML-based). Invoices can also conform to the European standard EN 16931. PEPPOL is not the primary delivery channel in Spain, unlike in Belgium, Germany, or France.

There is no date yet. SMEs and autónomos fall in the second phase, which takes effect 24 months after the ministerial order for the AEAT public platform enters into force. Real Decreto 238/2026 is already in force, but that order is not, so the countdown has not started. The 2026–2027 dates often quoted are estimates, not law. Always verify with the Spanish Tax Agency (AEAT).

FACe (Punto General de Entrada de Facturas Electrónicas) is Spain's B2G e-invoicing portal, mandatory for invoicing public sector entities since 2015.

Invoicia generates PEPPOL BIS Billing 3.0 XML (EN 16931 compliant), suitable for cross-border invoicing with Spanish customers. For domestic Facturae format invoicing, a Spanish accounting system with Facturae support is recommended.

To send an e-invoice in Facturae format in 2025, you need invoicing software that supports Facturae 3.2.x — Spain's national XML format. Generate the digitally signed XML file using a recognised electronic certificate and submit it through the platform agreed with your customer, or for public sector invoicing, via the FACe portal. For cross-border invoicing, PEPPOL BIS Billing 3.0 (EN 16931 compliant) is also accepted and supported by Invoicia.

PEPPOL plays a secondary role in Spain compared to other EU countries. Spain's domestic e-invoicing is built around Facturae and the FACe B2G portal, not the PEPPOL network. However, PEPPOL BIS Billing 3.0 (which is EN 16931 compliant) is valid for cross-border invoicing with Spanish customers who accept EU-standard e-invoices. For international companies that invoice Spanish B2B customers across borders, PEPPOL BIS Billing 3.0 is the recommended format. Invoicia generates PEPPOL BIS 3.0 XML out of the box, making cross-border invoicing with Spain straightforward.

Yes, partially. Foreign companies that sell B2B to Spanish businesses above the revenue threshold may need to issue compliant e-invoices to their Spanish customers. For cross-border B2B invoicing, PEPPOL BIS Billing 3.0 (EN 16931) is widely accepted and is the format Invoicia generates. If your Spanish customers require Facturae format specifically, you will need Spanish-compatible invoicing software. For public sector (B2G) invoicing in Spain, all suppliers — domestic and foreign — must use the FACe portal with Facturae format.

Invoicia generates PEPPOL BIS Billing 3.0 XML, not Facturae XML directly. Facturae 3.2.x is Spain's national e-invoicing format and requires a Spanish electronic certificate (e.g. FNMT, Camerfirma) for digital signing. For domestic Spanish invoicing under Crea y Crece — where Facturae is mandatory — pair Invoicia (for PEPPOL cross-border invoicing) with a Spanish-native ERP or accounting tool (e.g. Sage, Holded, A3 Software) that handles Facturae signing and submission to FACe / FACeB2B. For invoicing Spanish customers from outside Spain, PEPPOL BIS 3.0 is the recommended cross-border format and Invoicia generates this on the free plan.

EN 16931 is the European standard semantic data model for e-invoicing, adopted under EU Directive 2014/55/EU. Both PEPPOL BIS Billing 3.0 and many country-specific formats (XRechnung, OIOUBL, EHF) implement EN 16931. Spain's Facturae 3.2.x format predates EN 16931 and is technically distinct, but the recently published Facturae 3.2.2 introduces optional EN 16931 alignment fields. In practice: for B2G invoicing in Spain, Facturae remains required (FACe portal); for cross-border invoicing into Spain, PEPPOL BIS Billing 3.0 (which is EN 16931 compliant) is widely accepted.

FACe (Punto General de Entrada de Facturas Electrónicas) is Spain's original B2G e-invoicing portal — mandatory for invoicing public sector entities since 2015. FACeB2B is the separate platform the Spanish government is developing specifically for business-to-business (B2B) structured e-invoicing under the Crea y Crece mandate. While FACe handles government invoicing using Facturae XML, FACeB2B is intended as the central exchange platform for private-sector B2B transactions. Companies above the €8M revenue threshold need to ensure they are connected to FACeB2B-compatible channels (in addition to maintaining FACe for public sector invoicing). The detailed technical specifications and go-live date for FACeB2B's mandatory operation are confirmed by the Spanish Ministry of Finance — always check AEAT's official guidance for the latest implementation schedule.

Yes — autónomos (self-employed individuals registered with the Spanish tax agency) are within scope of Ley Crea y Crece, but in the second phase. Autónomos and micro-enterprises (fewer than 10 employees and annual turnover under €2 million) are expected to comply by 2026–2027 under the phased rollout. Until then, PDF invoices remain acceptable. However, autónomos who invoice large companies that are already under the mandate may need to issue Facturae-compliant invoices to those customers before the SME deadline. For autónomos invoicing European customers outside Spain — for example, Nordic or Belgian companies — PEPPOL BIS Billing 3.0 is the recommended format for cross-border B2B invoicing, and Invoicia generates this on the free plan.

If you are a non-Spanish company without a Spanish VAT registration invoicing Spanish businesses across the EU border, you are not directly subject to Crea y Crece — but your Spanish customers may prefer or require structured e-invoices for their own internal compliance. For cross-border B2B invoicing into Spain, PEPPOL BIS Billing 3.0 (EN 16931 compliant) is widely understood and accepted. If your Spanish customer requires Facturae format specifically, you will need Spanish-compatible invoicing software with support for Facturae 3.2.x digital signing. For public sector (B2G) invoicing in Spain, all suppliers — including foreign companies — must use the FACe portal with Facturae format regardless of their country of establishment.