Electronic invoicing for businesses and public bodies (FACe)

Terms used

• FACe — FACe is the state portal where suppliers upload e-invoices for public bodies.
• Facturae — Facturae is Spain's structured electronic invoice format, used for public bodies and accepted between businesses.
• DIR3 — The DIR3 codes identify the public body you invoice: accounting office, managing body and processing unit.
• Autónomos — Autónomos are self-employed workers who register and pay social security as freelancers.
• AEAT — The AEAT is Spain's tax agency.
• Verifactu — Verifactu is a separate set of rules for invoicing software that records invoices for the tax agency.

Key rules

• Public bodies: Invoices to public bodies above 5,000 euros must be electronic and go through FACe or the body's own entry point.
• Business customers: Invoices between businesses will have to be structured e-invoices, introduced in phases, with large companies first and everyone else later.
• PDFs: A PDF or scanned invoice does not count as a B2B e-invoice.
• Consumers: Sales to private consumers do not need a B2B e-invoice.
• Free option: A free public e-invoicing solution is meant for small businesses and autónomos.

Which invoices must be electronic

There are two separate regimes. Which one applies depends on who you invoice.

• Public bodies: you must send e-invoices through FACe or the body's own entry point. This already applies, and it covers freelancers too.
• Other businesses (B2B): a newer law is phasing in e-invoices between all businesses and professionals, including autónomos.
• Consumers: invoices to private consumers are not covered.

The B2B regime is separate from Verifactu, the invoicing-software rules.

Invoicing public bodies through FACe

FACe is the general entry point for e-invoices to the central administration. Many regional and local bodies also use it. Others have their own entry point, so ask your client which one it uses.

Invoices of up to 5,000 euros do not have to be electronic. Above that, the invoice goes through FACe or the body's own entry point.

To send one:

1. Ask your client for its three DIR3 codes. They are also in its contract or order.
2. Create the invoice in Facturae format, with the three codes.
3. Sign it with a recognised electronic certificate.
4. Upload it on the FACe portal, or send it through the web service or your invoicing software.
5. Keep the registration number FACe gives you. You can use it to track the invoice.

FACe accepts Facturae versions 3.2, 3.2.1 and 3.2.2. Free tools exist to create and sign Facturae files, including a desktop app from the Ministry for Digital Transformation. Some public bodies add their own requirements, such as an order number, so ask before you send.

Invoicing other businesses

All businesses and professionals established in Spain will have to issue, send and receive e-invoices in their dealings with each other. Every business must also be able to receive them. The customer must be able to see whether the invoice is paid.

Timing. The rule starts in phases once the 2026 implementing regulation takes effect. Large companies, by turnover, come first, roughly 12 months after it takes effect. Everyone else, including autónomos and small businesses, follows roughly 24 months after it takes effect. For a small business that points to 2027 or 2028. Check your exact start date with the AEAT.

Format. A PDF or a scanned paper invoice does not count. The invoice must be structured and machine-readable, in UBL, CII or Facturae. It carries the usual invoice content plus payment status (paid or unpaid, and the date). The Ministry of Finance sets the exact technical fields.

Channel. You can use:

• a private platform that follows the standard formats and reports payment status;
• your own system;
• the free public solution run by the tax agency and the central administration, aimed at small businesses and autónomos who do not want to pay for software.

Ask the AEAT what is operating now.

Some cases, such as simplified invoices, may be excluded by the regulation. The Basque Country and Navarra have their own tax systems, so check how the rules apply there.

What to do now

If you invoice public bodies, set up a certificate and Facturae tool now. If you invoice businesses, find out which phase you fall in and check that your invoicing tool can receive structured e-invoices. The checklist below walks through this.

Timeline and deadlines

• Large companies, by turnover, must issue and receive B2B e-invoices: about 12 months after the implementing regulation takes effect

Check the exact dates in the official text of the regulation and with the AEAT, Spain's tax agency.

Documents you need

• An invoice in Facturae format, version 3.2, 3.2.1 or 3.2.2, for invoices sent to public bodies through FACe.

• A recognised electronic certificate, such as one from the FNMT or a DNIe, to apply the advanced electronic signature (normally XAdES) to each FACe invoice.

• The three DIR3 codes of the client public body: oficina contable (accounting office), órgano gestor (managing body) and unidad tramitadora (processing unit). The body gives them to you, and they appear in its contract or order.

• For invoices between businesses, a structured machine-readable invoice in UBL, CII or Facturae that carries the usual invoice content and the payment status (paid or unpaid, and the date).

Checklist

• Confirm whether your invoices go to other businesses, which need B2B e-invoices, to consumers, which do not, or to public bodies, which follow FACe.

• Find out which phase your business falls in and the date it starts, with the AEAT.

• Choose how you will exchange B2B e-invoices: a private platform, your own system or the free public solution.

• Check that your invoicing tool can receive e-invoices in a structured format.

• Ask your public body client for its three DIR3 codes and whether it uses FACe or its own point of entry.

• Create the FACe invoice in Facturae format and include the three DIR3 codes.

• Keep the registration number FACe gives you and track the invoice status.

Official portals and guidance for invoicing and e-invoices

Official places to check invoicing rules

• AEAT, Spain's tax agency (online office): Check the current invoicing rules and the Verifactu invoicing software system in the invoicing sections of the tax agency's online office.

• FACe, the general entry point for e-invoices to public bodies: Send e-invoices to public bodies through FACe when the invoice is above the threshold, or use the body's own entry point.

• Ministry of Economy and the AEAT: Follow their guidance for business-to-business e-invoicing, as the detailed rules were still being developed.

Frequently asked questions

Do PDF invoices count as electronic invoices between businesses?

No, a PDF or a scanned paper invoice does not count as a B2B e-invoice. The invoice must be structured and machine-readable, in a format such as UBL, CII or Facturae. Other formats agreed between you and your customer also work if they can be converted to the standard.

Do I need an e-invoice when I sell to consumers?

No, sales to consumers are not covered by the B2B e-invoicing obligation. The obligation applies to invoices between entrepreneurs and professionals, including autónomos and companies. Invoices to public bodies follow the separate FACe rules.

Can a small business e-invoice without buying software?

Yes, the state offers a free public e-invoicing solution, run by the AEAT and the central administration, to create, send and receive invoices. It is designed for small businesses and autónomos. Check with the AEAT what is operating now.

What if my client public body does not use FACe?

Then you send the invoice through the other point of entry that the body uses, since many regional and local bodies have their own. Ask the body which point of entry it uses and for its three DIR3 codes. Some bodies also ask for extra details such as an order number.