Spain's Electronic Invoicing 2025

Understanding Royal Decree 1007/2023

On December 6, 2023, Royal Decree 1007/2023 was published in the Official State Gazette (BOE), approving the regulation establishing the requirements for computer or electronic systems and programs used in the invoicing processes of entrepreneurs and professionals.

From July 1, 2025, it will be mandatory for all entrepreneurs and professionals to have adopted computer or electronic systems and programs that support invoicing processes. Exceptions include:

• Taxpayers who keep books of records through the AEAT e-Office via electronic supply of invoicing records (SII) are exempt.
• Taxpayers under various special regimes are also exempt.
• Exemptions are provided for invoices from transactions through permanent establishments abroad.

Producers and marketers of invoicing programs will have 9 months to introduce them into the market following the publication of the ministerial order (yet to be developed).

The primary purpose of this regulation is to prevent software manipulation aimed at tax evasion. The requirements for the computer or electronic systems and programs supporting invoicing processes must adhere to principles of integrity, preservation, traceability, and unalterability of records, as stipulated in Law 11/2021 on measures to prevent and combat tax fraud.

The regulation aims to:

• Reinforce the obligation to issue invoices for all transactions.
• Ensure transactions are recorded in the computer system in a non-manipulable, accessible manner with a standardized structure and format, facilitating legibility of records and simultaneous submission to the tax authorities.
• Facilitate voluntary submission of invoices to the tax authorities for correct registration verification.
• Ease compliance with tax obligations.

This regulation ensures a specific framework that standardizes record formats containing information to be submitted to the tax administration. The extraction and provision of invoicing data must occur in its original format, without alterations to the records.