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The European Union is progressively moving towards the adoption of mandatory e-invoicing, but the implementation approaches vary widely among member states. Some countries have opted for centralized models, requiring businesses to process invoices through national platforms. Others depend on certified service providers to facilitate invoice exchange, while a few leave the method of invoice transmission entirely unregulated. Similarly, the pace of implementation differs: certain countries enforce the mandate in a single phase, whereas others take a gradual, step-by-step approach.
My earlier articles examined the diverse strategies for implementing mandatory e-invoicing in Poland, Belgium, France and Germany. This article turns the spotlight on Denmark and Spain, two countries that stand out for combining e-invoicing with broader digital transformation initiatives. These initiatives aim to digitize accounting processes and to mandate the use of certified billing systems, showcasing a comprehensive approach to enhancing compliance, efficiency, and transparency in financial operations.
Denmark
The Danish Bookkeeping Act of 2022 introduced new measures to advance the digitalization of financial record-keeping among businesses operating in Denmark. The Act establishes mandatory digital bookkeeping requirements that apply to a broad spectrum of businesses, regardless of their size or legal structure. These requirements cover two primary categories: businesses legally obligated to maintain accounts and other entities with annual net revenue exceeding DKK 300,000 for two successive years.
The Act mandates the use of digital bookkeeping systems that comply with specific standards set by the Danish Business Authority. Businesses can choose between two types of systems:
Registered accounting systems: These are standardized, pre-approved digital accounting systems registered with the Danish Business Authority. Providers of such systems must ensure full compliance with the Act’s requirements to be included on the official list of approved systems.
Custom-developed systems: Businesses may also opt for bespoke digital systems tailored to their unique operational needs. While these systems are not required to be registered, they must still adhere to the Act’s standards and requirements.
The transition to compliant digital bookkeeping systems is implemented in phases, allowing businesses ample time to adjust:
July 1, 2024: Companies obligated to submit annual reports under the Danish Financial Statements Act and using registered systems must comply.
January 1, 2025: Compliance is extended to companies using non-registered systems.
2026: Personally owned businesses with an annual net revenue exceeding DKK 300,000 for two consecutive years must comply.
An important aspect of the Act is its requirement for digital bookkeeping systems to support electronic invoicing. Under the Act, e-invoices are defined as invoices or credit notes issued, sent, and received in a structured electronic format that enables automated processing. While the Act does not currently mandate the issuance or receipt of e-invoices for business transactions, this provision ensures businesses are equipped with the necessary infrastructure should e-invoicing become mandatory in the future. Additionally, the Act grants the Minister for Business, in consultation with the Minister for Taxation, the authority to introduce rules mandating e-invoicing at a later date.
Spain
Spain is undertaking a substantial modernization of its tax and invoicing systems through two regulatory initiatives: the Crea y Crece law and the VeriFactu regulation. Both measures share the common goals of enhancing fiscal transparency and combating tax fraud, yet they differ significantly in their objectives and scope. The Crea y Crece Law mandates the adoption of e-invoicing for business-to-business (B2B) transactions. This regulation focuses on standardizing invoicing formats and establishing specific channels for the exchange of e-invoices between businesses. In contrast, the VeriFactu legislation is centered on ensuring the secure storage and traceability of invoicing data within software systems. Its primary aim is to create a robust framework for the integrity and reliability of invoicing records.
Mandatory e-invoicing
Spain’s mandatory e-invoicing initiative is grounded in the Crea y Crece Law, which aims to require all companies and self-employed individuals to issue and receive invoices in an electronic format. The mandate will apply exclusively to B2B transactions between companies established in Spain, excluding business-to-consumer (B2C) transactions and simplified invoices from its scope. E-invoice exchange will be facilitated through private platforms, public platforms, or a combination of both. Private platforms must adhere to stringent interoperability standards and ensure seamless transmission of invoices to the public invoicing platform.
The initial rollout of mandatory e-invoicing in Spain, originally anticipated for 2025, has faced repeated delays due to the complexity of the technical framework required to support the system. A draft decree outlining the technical framework was open for public consultation until July 10, 2023, but it has not yet been formally adopted. Once finalized, the regulations will include a phased implementation schedule based on business size:
Large enterprises: Businesses with an annual turnover exceeding €8 million will be required to comply 12 months after the technical regulations are published.
Small and medium-sized enterprises and self-employed individuals: These entities will have 24 months from the publication of the final regulations to comply.
This gradual rollout is designed to give businesses of all sizes adequate time to adapt to the new requirements without causing significant disruptions to their operations. Although the exact implementation date has yet to be confirmed, 2027 is emerging as the likely timeline, contingent on final approval of the implementing regulations.
Certified billing systems
The VeriFactu regulation will mandate the use of certified billing systems to ensure the authenticity, integrity, and traceability of invoices. It will apply to all businesses and professionals issuing invoices within Spain, except for two categories: entities that already submit real-time invoice data under the Suministro Inmediato de Información (SII) system, and foreign entities with a Spanish VAT number but without a permanent establishment in Spain.
Although the regulation was initially scheduled for implementation on July 1, 2025, the timeline has been revised. The new proposed deadlines are:
January 1, 2026: For corporate taxpayers.
July 1, 2026: For self-employed individuals.
On October 28, 2024, the Spanish Ministry of Finance published a ministerial order specifying the technical requirements for these billing systems. Certified billing software must meet strict criteria to ensure data integrity and support potential real-time reporting. Once a billing record is generated, it must be immutable, with any modifications creating an audit trail to document changes. While real-time invoice submission is not yet mandatory, systems must be designed to accommodate this functionality for a seamless transition if it becomes required in the future. This requirement aligns with Spain’s broader efforts to implement a B2B electronic invoicing mandate, which remains under development.
Another critical feature of VeriFactu is the mandatory inclusion of a QR code on all invoices, including standard and simplified formats. If an invoice is reported to the Spanish tax authorities (AEAT) in real time, it must also display the statement: “Factura verificable en la sede electrónica de la AEAT” or simply “VeriFactu.” This allows customers to verify the invoice’s authenticity directly with the tax authority by scanning the QR code.
Businesses can choose between two options for certified billing systems:
Verifiable Invoice Issuing Systems (VERI*FACTU Systems): This option involves the automatic submission of invoice data to the tax authorities. It is technically simpler, as it does not require advanced features such as digital signatures or event registration. Invoices submitted under this option are verifiable directly through the tax authority’s portal, enhancing transparency and ensuring compliance.
Other Systems (Non-VERI*FACTU Systems): Businesses that opt out of real-time reporting must comply with stricter technical requirements. These include the use of digital signatures to ensure invoice authenticity and event registration to document all invoice modifications, creating a clear audit trail. While this option may appeal to businesses seeking greater control over their data, it may expose them to a higher risk of tax audits, as tax authorities lack immediate visibility into their transactions.
Staying ahead
The journey toward mandatory e-invoicing across Europe exemplifies the broader trend of digital transformation in tax and financial compliance. Spain and Denmark serve as compelling examples, integrating e-invoicing within their comprehensive tax transformation initiatives. These efforts underscore the diverse approaches countries take to achieve shared goals of transparency, efficiency, and fraud prevention. Even in countries where e-invoicing is not yet mandatory, businesses increasingly face the obligation to equip their billing systems with e-invoicing capabilities. This readiness will allow them to stay ahead of regulatory developments and adapt seamlessly should e-invoicing mandates be introduced.
The opinions expressed in this article are those of the author and do not necessarily reflect the views of any organizations with which the author is affiliated.
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Publish date : 2025-01-12 05:34:00
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