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In Portugal, e-invoicing rules differ between the public and private sectors. For B2G, electronic invoicing is mandatory under decree-Llaw 111-B/2017, which brought the EU directive on public procurement into national law. Large companies are required to issue structured e-invoices since 2021, while small and medium-sized suppliers, as well as micro-enterprises, must comply from 1 January 2026. Public administrations have been obliged to receive and process e-invoices since 18 April 2019, using the national CIUS-PT (a local implementation of EN 16931). Exchange takes place either via the centralised eSPap platform or through service providers designated by each public entity.
For B2B, there is no general mandate yet, but general invoicing rules already apply. All invoices must be created using AT-certified software, reported to the tax authority via the SAF-T billing file, and include a QR code, ATCUD, and hash for authenticity. From 2026, PDF invoices will also need a qualified electronic signature to be considered as a valid e-invoice.
Portugal is also preparing to extend SAF-T reporting: from 2027, companies will need to submit the full accounting SAF-T file for the 2026 financial year.
| Mandate Status | Mandatory |
| Mandate Scope | B2G |
| Model Type | Clearance |
| Government Entity | Autoridade Tributaria y Aduaneira (AT) |
| Formats | UBL 2.1, CII (Cross Industry Invoice) |
| Infrastructure / Platform | FE-AP (eSPap) |
| E-signature Required | Qualified electronic signature (QES) will become mandatory on PDF e-invoices from 2026. |
| Key Deadlines | 18 April 2019: Public administrations and institutions were required to adapt their systems to be able to receive and process electronic invoices. 1 January 2021: The mandate for issuing e-invoices to public entities became effective for large companies. 1 January 2023: Mandatory use of the unique document code (ATCUD) and QR code on all invoices. 1 January 2026: - SMEs, micro-enterprises and public entities as co-contractors must comply with the B2G e-invoicing mandate - Qualified electronic signature (QES) on PDF e-invoices becomes mandatory |
| AR Mandatory | Yes. Mandatory for suppliers to the public administration (B2G). |
| AP Mandatory | Yes. All Portuguese public entities must be able to receive e-invoices. |
| Peppol Available | No |
| Domestic Transactions | B2G e-invoicing is mandatory for all suppliers of public entities. B2B/B2C e-invoicing is not yet, but all invoices must be reported through the SAF-T billing process and include ATCUD, hash, and QR code. |
| Cross-border Transactions | No. The e-invoicing mandate doesn’t apply to cross-border transactions, except for suppliers to public administrations. That being said, all issued invoices must still be reported through the SAF-T billing process. |
| Archiving Period | 10 years |
| Archiving Abroad | Archiving outside Portugal is allowed if integrity, readability, and accessibility for the Portuguese Tax Authority are ensured. |
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