e-Invoicing in Portugal [2024 Requirements]

Implementation timeline

On January 1, 2021, an obligation for large entities and public authorities as cooperating entities came into force.

On January 1, 2023, mandatory ATCUD and QR codes were implemented.

On January 1, 2024, an obligation for micro, small, and medium-sized enterprises, as well as public authorities as cooperating entities, came into force.

On January 1, 2026, companies in use of PDF invoices must include a Qualified Electronic Signatures (QES) or a Qualified Electronic Seal, issued to taxpayers by certified third-party provider.

E-invoicing process description

B2G e-invoicing is mandatory in for large entities as of January 2021. In order to transfer and receive B2G e-invoices, suppliers and direct public administration entities are connected to the ESPAP’s portal FE-AP, the gateway of the state to financial documents. The documents are being transferred through a secure online connection (web-service). Generally, invoices must contain a QR code as of January 1, 2022 (though the QR code may be bypassed for taxpayers using electronic data interchange (EDI). As of Jan 1, 2023, ATCUD number must be allocated by the tax authorities for batches of invoices prior to their issuance. PDFs are considered as e-invoices if issued by Dec 31, 2023.

SAF-T Accounting – Current Status

Portugal intends to introduce mandatory SAF-T Accounting from 2027 (covering 2026) and from the same date e-signature requirement in PDFs will be introduced. On July 19, 2023, the Portuguese government informed through the eSPAP that the deadline for introducing the obligation to e-invoicing with public entities for other entrepreneurs is as follows: from January 1, 2026, an obligation for micro, small and medium-sized enterprises and for public authorities as cooperating entities will come into force.

In December 2023, the Portuguese Tax and Customs Authority decided to postpone introducing a requirement for the invoices in PDF format to feature the qualified electronic signature. The original plan was to oblige issuers to sign their invoices electronically on January 1, 2024. This, however, is being pushed back an entire year to January 1, 2026.

All resident taxpayers are required to submit the SAF-T reporting information on a monthly basis:

Sales invoices

Transport logistics document support

Cash receipts for the VAT cash accounting scheme

B2G & B2B E-invoicing

In B2G, e-invoicing became mandatory for large enterprises in 2022. As of January 2023, this obligation has applied to medium-sized, small, and micro-companies.

Large enterprises: more than 250 employees, annual sales over EUR 50 million, balance sheet total of EUR 43 million

Medium-sized companies: fewer than 250 employees, annual sales no more than EUR 50 million, balance sheet total no more than EUR 43 million

Micro-companies: fewer than 10 employees, annual sales or balance sheet total no more than EUR 2 million

When it comes to B2B e-invoicing, Portugal is not planning an obligation because they have other ways to monitor VAT: QR codes, ATCUD codes (2023), SAF-T for invoicing (current) and soon SAF-T accounting from 2027 (covering 2026).

Archiving requirements for e‑Invoicing in Portugal

Storage period: 10 years.

What is the required format of an e-invoice

For B2G: The standards UBL 2.1 CIUS-PT or CEFACT CIUS-PT are to be complied with.

Platform

For B2G:

Portal BASE (general e-procurement)
Plataforma Eletrónica de Compras (eSPap platform)

Tax authority

AT - Autoridade Tributária e Aduaneira

Invoice mandate model

B2B invoicing type - post-audit
E-signature - mandatory

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