Electronic invoice and crypto: what you should know as a freelancer or company

Law 18/2022 (Create and Grow Law) introduced the electronic invoice obligation for all B2B relationships in Spain. In 2025 and 2026 its implementation is being completed. If you get paid in cryptocurrencies, this affects you.

What is mandatory electronic invoice?

The electronic invoice is an invoice document in structured format (XML/JSON) that:

• It is exchanged between sender and receiver by electronic means.
• Follows the Facturae standard or the new Verifactu standards.
• For B2C (individuals): it can also be in PDF or other formats if there is consent.

Who is obligated (2025-2026)

• Companies with turnover >€8M/year → already obligated since July 2025.
• Rest of companies and self-employed workers → obligated from 2026 (see BOE for updates).

What is Verifactu?

Verifactu is the AEAT system that requires billing systems to send in real time (or in batch) the invoices issued to the AEAT records. Replaces the SII system (Immediate Information Supply) for those who already use it.

How do I issue an invoice if I charge in crypto?

If you are self-employed or a company and charge in USDT, BTC, ETH or another crypto:

1. The invoice must be issued in EUROS with the description of the service provided.
2. Includes the amount of the equivalent consideration in EUR.
3. You can add a note: "Paid in [amount] [crypto] equivalent to [X]€ at the exchange rate of [date] according to [source]."
4. VAT is calculated on the EUR value (not on the crypto value directly).

Example of invoice with payment in crypto:

Concept: Development of smart contracts – March 2026
Tax base: €5,000.00
VAT 21%: €1,050.00
Total invoice: €6,050.00

Payment method: 0.0756 ETH equivalent to €6,050.00 according to the quote on 03/05/2026 on Kraken (ETH/EUR).

VAT on crypto charges

VAT applies to the value in euros, no matter how it is paid. If the 21% VAT is €1,050 and the customer pays in ETH, you should receive enough ETH to cover the total €6,050.

The moment of VAT accrual

VAT is accrued when the service is provided or at the time of collection (whichever occurs first). Not when you convert ETH to EUR.

Accounting records

For payment in crypto, the accounting entry would be (simplified):

• Debit: Virtual currencies (current assets) for the EUR value of the ETH received.
• Credit: Customer (collections) for the same value.
• If you then sell the ETH at a different price: difference → financial result.

The exchange rate: which one to use?

There is no official rule that specifically determines which one to use. Reasonable options:

1. Closing price on Binance/Kraken on the day of the invoice or collection.
2. Average price of the day on CoinMarketCap.
3. Official rate of the European Central Bank (does not exist for crypto → use market reference).

Always document the exchange rate used, the source and the date.

Withholdings on invoices collected in crypto

If the client must withhold income tax from you (e.g., you are a professional self-employed person and the client is a company):

• The withholding (e.g.: 15%) is deducted from the total in EUR.
• The client pays: (base + VAT) × (1 − withholding) in crypto equivalents.
• The client pays the withholding to the AEAT in EUR (will have to convert).

The simplified invoice for anonymous crypto customers

If you sell a digital service (e.g. access to crypto software) to anonymous users who pay with crypto:

• You can issue simplified invoices (tickets) without buyer information if they are transactions of less than €400 (or without a maximum amount if the recipient is a private individual).
• For users who do not provide personal data (wallet only): simplified invoice in most cases.

Verifactu and payments in crypto

With Verifactu, invoices will be sent in real time to the AEAT. If the amount is in EUR (even if the payment is in crypto), the system works like any other invoice. There is no special treatment for the payment method.

Updated: April 2026 | Fiscal year: 2025