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Spain: Extended deadline for adapting e-invoicing software, new exemption in certain cases of invoicing by recipient or third party

Amendments to electronic invoicing (e-invoicing) systems regulations introduced by Royal Decree 254/2025

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April 14, 2025

Royal Decree 254/2025 (published in the official gazette on April 2, 2025) introduced the following amendments to the regulations providing guidance regarding the required technical, functional, and content specifications for electronic invoicing (e-invoicing) systems, which became effective October 29, 2024 (read TaxNewsFlash):

  •  Extended deadline for adaptation of e-invoicing software
    • January 1, 2026 (extended from July 1, 2025) for corporate income taxpayers (except exempt entities, to which this new obligation does not apply)
    • July 1, 2026 for all other taxpayers (i.e., individual income taxpayers, nonresident income taxpayers operating through a permanent establishment (PE), or entities subject to the passthrough regime)
    • July 29, 2025 (nine months from October 29, 2024) for producers and retailers of e-invoicing systems to place e-invoicing systems that meet these specifications on the market
  • New exemption for transactions documented by means of invoices that are materially issued by the recipient of the transaction, or by a third party as a result of the application of mandatory regulatory provisions, provided they keep their records in accordance with the terms of article 62.6 of the Value Added Tax (VAT) regulations approved by Royal Decree 1624/1992 of December 29, 1992 (i.e., within the immediate supply of information or “SII” system)

Read an April 2025 report prepared by the KPMG member firm in Spain

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