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Spain

Spain stacks four separate layers - Facturae/FACe for B2G, an enacted but not yet fully dated B2B mandate, SII VAT reporting, and VERI*FACTU from 2027 - and none of them is solved by Peppol alone.

Profile last verified 2026-07

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At a glance

Cross-border and voluntary structured exchange served over Peppol today; Spain's regulated B2G and tax-reporting flows run on national rails.

Exchange model
Mixed
B2B mandate
Enacted by Law 18/2022; phased start expected around 2027–28, exact dates pending final regulation
B2G e-invoicing
Mandatory for suppliers to public administrations since 15 January 2015, via FACe in Facturae format
Formats
Facturae XML (B2G, via FACe, with XAdES signature) · EN 16931 syntaxes (UBL / CII) for the planned B2B regime · Peppol BIS Billing 3.0 (cross-border and voluntary exchange)
Peppol identifier schemes
9920
Spanish VAT / NIF number (ES:VAT)
The Peppol scheme for Spanish participants; regulated B2G invoices additionally need DIR3 administrative routing codes, which are not Peppol identifiers
E-reporting
SII near-real-time VAT reporting live since July 2017 for large taxpayers; the VERI*FACTU certified-software regime phases in from 2027
What to know
Spain's regulated flows run on national rails - B2G through FACe in Facturae, VAT reporting through SII and VERI*FACTU, and the coming B2B regime through an interoperable platform model; Recommand serves cross-border and voluntary exchange over Peppol today, with FACe and AEAT connectors on the roadmap.
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Mandate timeline

15 Jan 2015
B2G e-invoicing mandatory for covered public-sector invoices, submitted through FACe as Facturae XML
1 Jul 2017
SII near-real-time VAT reporting starts for large companies, VAT groups, and monthly-refund taxpayers
29 Sep 2022
Law 18/2022 published, creating the B2B e-invoicing mandate framework
1 Jan 2027
VERI*FACTU certified invoicing-software regime starts for Corporate Income Tax taxpayers (others from 1 July 2027)
~2027–28
Expected phased B2B e-invoicing start: businesses above €8m turnover first, all others a year later - dates to be confirmed in final regulation
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How Recommand serves Spain

  • Exchange structured invoices with Spanish counterparties over Peppol today for cross-border and voluntary flows - Recommand is a certified Access Point and SMP, addressing participants under their VAT number (9920)
  • Built-in EN 16931 validation covers the syntaxes Spain's planned B2B regime will accept as a minimum (UBL and CII)
  • Regulated B2G invoices need FACe submission in Facturae format with DIR3 routing - a national rail on Recommand's roadmap, not something a Peppol connection covers
  • Once Spain's final B2B technical rules are published, platform interoperability and status reporting ship as platform updates - Recommand will not claim Spanish mandate compliance before the rules support it
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Frequently asked questions

01Is e-invoicing mandatory in Spain?

For suppliers to public administrations, yes - since 15 January 2015, through FACe in Facturae format. For B2B, the obligation is enacted in Law 18/2022 but its operational start is regulation-triggered: larger businesses (above €8m turnover) go first, expected around 2027, with all others about a year later. Exact dates must be verified against the final published rules.

02Can I reach Spanish public administrations over Peppol?

No. Spanish public-sector invoices must be submitted as Facturae XML through FACe or a connected entry point, routed with DIR3 administrative codes. Peppol is not the mandated B2G channel in Spain.

03What are SII and VERI*FACTU, and are they e-invoicing?

Neither delivers invoices to your customer. SII is near-real-time VAT-register reporting to the tax agency (AEAT), live since 2017 for large taxpayers. VERI*FACTU is a certified invoicing-software regime phasing in from 2027 that generates tamper-proof invoice records. They are separate compliance layers on top of invoice exchange.

04Which Peppol identifier do Spanish companies use?

The Spanish VAT/NIF number under scheme 9920. That is enough for ordinary Peppol reachability; regulated flows additionally need Spain's national routing and reporting data.

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