Spain starts countdown to major invoice change affecting autónomos and businesses

Millions of autónomos and small business owners in Spain are now officially on the clock for a major change to the way they send and receive invoices, after the Government triggered the countdown towards mandatory electronic invoicing. The change will eventually affect almost everyone who invoices other businesses in Spain, including foreign residents who work for themselves, and it goes much further than simply swapping a paper invoice for a PDF. 

Autónomos have until October 2028 to switch 

Hacienda (Spain’s tax agency) has published the order that starts the countdown, appearing in the Official State Gazette (BOE) on Monday October 5 and coming into force the next day, Tuesday October 6.

The clock runs in two tiers. Businesses with more than €8 million in annual turnover have 12 months, which takes them to around October 2027, while everyone else, including autónomos (the self-employed), has 24 months, taking the deadline to around October 2028.

So there’s no need to panic just yet, though the change is bigger than most people assume.

A PDF won’t count as an electronic invoice

This isn’t just about emailing an invoice instead of physically writing one either. An electronic invoice under the new system has to be a structured file, meaning data that software can read and exchange automatically, in formats including UBL (a standard computer-readable invoice format) or Facturae (Spain’s own version).

A PDF on its own just won’t do, because it’s essentially a picture of an invoice that a computer can’t process.

Now there’s a second part too. The business receiving an invoice will have to report back on what happens to it, including whether it’s accepted or rejected and when it’s paid in full, with the status updates due within four working days.

Self-employed individuals do get an extra 12 months on that reporting side, so it will reach them later than the invoicing itself.

The tax agency’s free tool is on the way

Hacienda will run its own free public platform where invoices can be created and sent, and it will also act as a central store for the invoices that pass through it. It has to be available at least two months before the first deadline, and users will log in with a digital certificate or Cl@ve (Spain’s online ID system).

Autónomos who’d rather not pay for invoicing software will be able to use it instead. Private platforms are still allowed, though they’ll have to send a copy of every invoice to the public system at the same time. 

Customers who aren’t businesses are left out

The rule only covers invoices between businesses and professionals when the customer is based in Spain. Sales to private individuals aren’t included, and neither are simplified invoices (the shorter tickets used for small sales). 

That matters for the many foreign residents who work for themselves, because someone invoicing mostly homeowners or holidaymakers will see little change. Anyone billing Spanish companies or other autónomos, however, will be in the system.

With two years to go, the sensible first step for anyone who invoices other businesses is to ask their gestor (accountant) or invoicing software provider whether they’ll be able to produce structured invoices, and to keep an eye out for when Hacienda’s free tool launches.