Since the rollout of e-invoicing in Spain last January, different difficulties have emerged that prevent optimum use of this system. Administrations and suppliers alike have failed to comply with the rights and obligations demanded by this type of billing. To this end, in an attempt to improve the situation, on March 24 the Official State Gazette published an Amendment to Law 25/2013.
The amendment includes changes to five articles of the regulation. The majority are related with regulation of general entry points for e-invoicing in the different agencies. The amendment also addresses other issues related with accounting records for invoices. The aim is to encourage more rigorous control of documents and expedite payment deadlines.
What are the changes?
- The amendment specifies the right of suppliers to receive detailed information on e-invoicing through the agency determined by each Administration (article 4).
- Regarding the general point of entry for e-billing, it states that local bodies may use the points provided by their own local or provincial council, autonomous community (region) or state. In addition, it states that the regions may also join FACe (article 6.1).
- In those cases where the Public Administration has no general point of entry, or is not using that of another Administration, suppliers are entitled to submit their e-invoicing via FACe. The document will then be left in a repository, “where the pertinent Administration shall be responsible for access to and management and processing of the same” (article 6.7).
- Article 6.8 includes the obligation of provincial councils, local authorities and island councils to collaborate and provide the necessary technical means for Facturae in municipalities with fewer than 20,000 inhabitants.
- As for accounting records of invoices, it states that these may connect with other general entry points and with FACe, as long as the corresponding Administration has already signed up. It also states that the entry of the invoice in the register will result in the automatic assignment of an identification code, which must be communicated immediately to the general points of entry with which it is interconnected (article 9).
- Another new feature highlighted is that a new section is included in article 12, announcing an annual systems audit to check that the accounting records are functioning properly. This report will also include an analysis of the average time taken to enter invoices in the register and the number of e-invoices rejected at this stage, as well as the reasons.
- Finally, the Ministry of Finance and Public Administration is committed to maintaining an updated directory with the e-addresses of the general points of entry of the General State Administration, regional governments and local authorities. The aim is that suppliers should be able to consult this and other supplementary information that may be useful to them.