Invoicing in an online shop without picking the wrong document

Every sale carries a document, even if the customer never asks

The duty to document a sale does not arise from the customer asking: it arises from the transaction itself. Article 2.1 of the Invoicing Regulation (RD 1619/2012), which implements article 164.One.3 of the VAT Act, requires a business or professional to issue an invoice and a copy for the supplies of goods and services carried out as part of their activity, including those outside the scope of VAT and those that are exempt. It also requires an invoice for payments received before the supply, which is exactly what happens in a shop that charges when the order is confirmed and ships afterwards.

Paragraph 2 of that article shuts the door on exceptions in precisely the situations that look like e-commerce: an invoice must be issued in every case when the recipient is a business or professional acting as such, when any recipient demands it in order to exercise a tax related right, for supplies to another member state under article 25 of the VAT Act, for the distance sales under article 68.Tres(a) deemed to take place in Spanish territory, for the exports under article 21.1 and 21.2, and when the buyer is a legal person not acting as a business, or a public administration.

There is one real exception, and it affects many product shops: article 3.1(b) releases from the general duty anyone selling under the recargo de equivalencia, the mandatory VAT scheme for retailers trading as individuals. Released from the general rule, not from the cases in paragraph 2: if the buyer is a business, if someone demands the invoice to exercise a tax right, or if the sale crosses the border, the document still has to be issued.

And a vocabulary mix-up worth clearing early: a till receipt without the minimum data of article 7.1 is not a simplified invoice, even though retail speech treats the two words as synonyms. What tells them apart is not the paper or the size, it is the content. If you are also going to issue full invoices, the guide on your first invoice goes through all of their compulsory fields.

The simplified invoice: 400 euros, and 3,000 for retail

Article 4 of the regulation sets two different ceilings for using a simplified invoice instead of a full one. The first, under article 4.1(a), is general: a simplified invoice is allowed «when its amount does not exceed 400 euros, Value Added Tax included». Letter (b) of the same paragraph also allows it when what is being issued is a credit note.

The second ceiling, under article 4.2(a), is more generous but does not cover every transaction: up to 3,000 euros, VAT included, on retail sales, which the regulation itself defines as supplies of tangible movable goods or livestock where the recipient does not act as a business or professional but as the final consumer. And it carries a carve-out almost nobody reads: sales are not treated as retail when their object is goods that, by their objective characteristics, packaging, presentation or state of preservation, are mainly for business or professional use. A shop selling technical equipment or machinery cannot assume the 3,000 euro ceiling just because the buyer is a private individual.

That same paragraph 2 extends the 3,000 euros to a closed list of services: hospitality and catering, hairdressing and beauty salons, dry cleaning and laundry, parking, photo developing, sports facilities, passenger transport and a few more. If your shop sells services that are not on that list, your ceiling is the general one of 400 euros, not 3,000.

Above whichever ceiling applies to you, the invoice has to be a full one, with all the data of article 6, whatever kind of customer it is. It is worth programming that cut-off into the system rather than trusting whoever prepares the order to remember it: a 3,200 euro order documented with a simplified invoice does not become valid because nobody noticed in time, and fixing it later means tracking the customer down and reissuing the document.

What a simplified invoice carries, and which series the regulation forces apart

Article 7.1 lists what a simplified invoice has to carry: a number and, where applicable, a series, sequential within each series; the date of issue; the date of the transaction or of the advance payment when it differs from the date of issue; the tax number and the name or company name of the issuer; an identification of the type of goods supplied or services provided; the VAT rate applied and, optionally, the wording «VAT included», with the taxable base broken down per rate when there are several; the total consideration; and, on credit notes, an express and unambiguous reference to the invoice being corrected.

What it does not carry matters as much as what it does: it does not identify the buyer. That is why a simplified invoice is not enough for a business customer to deduct input VAT, and why the regulation gives that customer the right to ask for it to be completed, as the next section explains.

Series deserve a paragraph of their own, because there is a duty here that almost nobody applies. The last paragraph of article 7.1(a) states that when a trader issues, within the same calendar year, invoices under article 7 (simplified) and under article 6 (full), issuing them through separate series is compulsory. A shop that invoices consumers with simplified invoices and businesses with full ones therefore needs two series, not one.

Article 6.1(a) fills in the rest of the map: separate series may be opened when there are reasons justifying it, and it names two cases that fit e-commerce, having several establishments from which you operate and carrying out transactions of a different nature. That is the basis for running one series per sales channel, one for the physical shop and another for the online one. It also makes specific series compulsory in five cases, among them credit notes and invoices issued by the recipient or by a third party on your behalf.

When the simplified invoice is forbidden: article 4.4

Paragraph 4 of article 4 lists the transactions where a simplified invoice cannot be issued. Two of them matter in an online shop, and the second one is almost always told backwards.

The first is article 4.4.a): supplies of goods destined for another member state referred to in article 25 of the VAT Act, that is, the exempt intra-EU supply to a buyer that is a business with a valid EU VAT number. There the invoice is always a full one, carrying the buyer's VAT number, and the transaction ends up on the modelo 349 return. The guide on invoicing foreign clients without VAT covers it.

The second is article 4.4.b): the supplies of article 68.Tres(a) of the VAT Act, except where the special scheme of section 3 of chapter XI of title IX applies to them, which is the Union scheme of the one stop shop. It is worth reading slowly what those supplies are, because the market tells it the other way round: article 68.Tres(a) covers intra-EU distance sales where Spanish territory is the place of arrival of the dispatch or transport. They are not the sales leaving Spain towards a consumer in another country.

Translated into real cases, article 4.4.b bites when the shipment comes in: the seller who stores stock in another EU country and ships it from there to a Spanish consumer, which is the usual European logistics arrangement on marketplaces, or the seller established in another member state who has passed the article 73 threshold or opted to be taxed at destination. On those shipments the simplified invoice is banned, and it only becomes available again if those sales are declared under the Union scheme.

That leaves the opposite question, the sale leaving Spain towards a consumer in another EU country. As long as the article 73 threshold is not exceeded (10,000 euros a year, tax excluded, for those sales and certain services taken together) and the option to be taxed at destination is not exercised, a sale by a seller established only in Spain is located here under article 68.Tres(b): it carries Spanish VAT and is documented like any other domestic sale, simplified invoice included if the amount allows. Once the threshold is passed or the option exercised, the sale is located in the country of arrival, and then the invoicing rules that govern are the ones in this regulation if you declare under the Union scheme with Spain as the member state of identification (article 2.3(a)), and those of the destination country if you are not in the scheme.

The customer is a business and asks for its tax number on the invoice

Article 7.2 gives a business or professional recipient the right to demand, for the purposes of article 97.One of the VAT Act (the one that conditions deduction on holding the invoice), that the simplified invoice be completed with two blocks: its tax number and its address, and the VAT charged shown separately instead of included in the price. Article 7.3 extends that right to someone who is not a business but needs the data to exercise any tax related right.

A simplified invoice completed that way is not a formality: it is what lets the buyer deduct. That is why it is worth collecting the tax number and the company name during the checkout itself, with a field that appears when the buyer states they are buying for a business, rather than waiting for a request that arrives weeks later. If that same catalogue is also sold through a marketplace, invoicing those sales follows rules of its own, covered in the guide on selling on a marketplace.

And if the request arrives late anyway? Article 15.6 settles the case with a sentence that saves a lot of work: invoices issued in substitution or exchange for simplified invoices issued earlier do not qualify as credit notes, provided those simplified invoices met the requirements of article 7.1. Nothing is voided and nothing is corrected: the full invoice replacing the simplified one is issued, and the transaction stays documented exactly once.

There is a side effect worth knowing before 2027. Article 8 bis of this same regulation points to Act 56/2007 for mandatory business to business e-invoicing and specifies that the duty does not apply where a simplified invoice under article 4 is issued, except for those referred to in article 7.2. In other words: as soon as a simplified invoice is qualified with the business buyer's tax number and address, it falls within the scope of business to business e-invoicing.

The deadlines: on the spot, or before the 16th of the next month

Article 11.1 sets the general rule without nuances: «invoices shall be issued at the moment the transaction takes place». When the recipient is a business or professional acting as such, the same article opens a longer window, up to before the 16th of the month following the one in which the VAT on that transaction became chargeable.

For a consumer shop, where most buyers are private individuals, that means the habit of issuing the document at the moment of the order is also what the law requires: there is no room to pile up invoices to consumers and issue them weeks later. The longer window of the 16th belongs to sales to businesses, and confusing the two is easy in a business that sells to both through the same channel.

Advance payment has a rule of its own, and it fits e-commerce like a glove. Article 75.Two of the VAT Act makes the tax chargeable, on payments made before the taxable event, at the moment of collection, in full or in part, on the amounts actually received, with the exception of the intra-EU supplies of article 25. Since article 2.1 of the regulation requires an invoice for those payments, a shop that charges on order confirmation and ships two days later already has a chargeable event and a document to issue, without waiting for delivery.

Two special deadlines are worth keeping at hand: for the intra-EU supplies of article 75.Uno.8 of the VAT Act, article 11.2 moves the issuing to before the 16th of the month following the start of the transport to the buyer; and under the special cash accounting scheme, article 11.3 repeats the general rule with the same exception for business recipients.

One invoice a month per customer: the recapitulative invoice

Article 13.1 allows several transactions carried out on different dates for the same recipient to be included in a single invoice, provided they took place within the same calendar month. Article 13.2 sets the deadline: at the latest, the last day of the calendar month in which the transactions took place, or before the 16th of the following month if the recipient is a business or professional acting as such. And article 13.3 brings that forward to the 16th of the month following the start of the transport for the intra-EU supplies of article 75.Uno.8.

It is a tool designed for relationships with repeat purchases, not for the occasional consumer: it makes sense in a shop selling every week to the same professional customers, and hardly ever in a consumer shop with one-off orders, where saving one document does not make up for tracking which transactions ended up grouped and in which invoice.

Because that tracking does not go away: grouping into one document does not merge the transactions. For VAT and record book purposes each grouped transaction still exists separately, with its own date and taxable base, only documented inside a shared invoice. If the system issuing the recapitulative invoice does not keep that detail, the record book stops matching the invoices.

A practical warning for shops with subscriptions or recurring deliveries: the recapitulative invoice groups transactions from the same calendar month, so it cannot be used to put transactions from two different months into one document, however much the billing cycle of the business straddles them.

Refunds: the credit note, its series and the later-supply exception

When a sale that has already been invoiced is returned, the original is neither deleted nor voided: a credit note is issued. Article 15.1 requires one when the original invoice fails to meet any of the requirements of articles 6 or 7, and article 15.2 when the VAT charged was determined incorrectly or when the circumstances of article 80 of the VAT Act that modify the taxable base arise, which is the drawer where returned goods live.

The second paragraph of article 15.2 keeps an exception that almost nobody uses: if the return of goods or of packaging happens on the occasion of a later supply to the same recipient, and an invoice was issued for the transaction in which they were supplied, no credit note is needed: the amount returned is subtracted from the amount of that later transaction, provided the VAT rate applicable to all the transactions is the same, whether the result comes out positive or negative.

Outside that case, the credit note has rules the system has to respect. Article 15.3 requires it to be issued as soon as the circumstance becomes known, with a four year limit from the chargeable event. Article 15.4 requires the new invoice to state the identifying details of the invoice being corrected, and allows several to be corrected in a single document provided all of them are identified. And, above all, article 6.1(a) requires credit notes to be issued in a specific series: it is not a matter of style, it is the only correct way to number them.

The costliest failure in an online shop is in none of those paragraphs, but in how the work is split: the refund is triggered by customer support from the payment gateway and nobody issues the credit note. The money goes back, the tax document still says the full amount was sold, and the VAT declared and the invoicing record stay out of line until somebody notices. How each document fits into the bookkeeping is explained in the online shop accounting guide.

Verifactu in an online shop: what changes in 2027

The Regulation on invoicing computer systems, approved by RD 1007/2023 and with its timeline moved by RD-ley 15/2025, requires the software used to issue invoices to meet a set of technical requirements, among them that the invoicing records be chained through a fingerprint and that invoices carry a QR code. The compulsory application dates are 1 January 2027 for companies and 1 July 2027 for the self-employed.

There is a bridge between the two regulations worth knowing, because it works in your favour: article 8.4 of the Invoicing Regulation states that the authenticity of origin and the integrity of content of the invoice are presumed to be established when it has been issued using a system or program compliant with the requirements of that regulation on invoicing computer systems. Complying with Verifactu does not only avoid a penalty: it also settles a burden of proof that otherwise has to be carried by business controls and a reliable audit trail.

For a shop, the first step is identifying which program actually issues the invoice: the shop platform, a connected invoicing module, or a separate accounting application. It is that system, and not the arrangement as a whole, that has to meet the requirements before the date that applies to it, and it makes no difference whether it issues simplified or full invoices: the requirement belongs to the system, not to the type of invoice. The standard is explained in what Verifactu is and, for people working on their own, in Verifactu for the self-employed.

And a buying warning: nobody can sell you a program «certified by the Spanish tax agency», because that certification does not exist. What the rules require from the software maker is a declaración responsable, a document with a prescribed content. Ask for it before you sign.

How kontora handles it

kontora issues your shop's invoices with their series, their sequential numbering and the chained Verifactu record, and generates the credit note in its own series when you process a return. It also covers the article 7.2 case: if the sale was documented with a simplified invoice and the buyer turns out to be a business, kontora issues the full invoice that replaces it, instead of correcting it. Every invoice goes out with the logo you upload in your company details. Signed electronic invoicing in Facturae format is included in every invoicing plan: kontora generates and signs the file, and uploading it to FACe is done by you. Nobody can sell you a program «certified by the Spanish tax agency», because that certification does not exist: what does exist is the maker's declaración responsable, and ours is in plain sight, with its print button, in your company's invoicing settings.

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