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In Portugal, e-invoicing rules differ between the public and private sectors.
For B2G, electronic invoicing is mandatory under decree-Law 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 2027, PDF invoices will also need a qualified electronic signature (QES) to be considered as a valid e-invoice.
Portugal is also preparing to extend SAF-T reporting: from 2028, companies will need to submit the full accounting SAF-T file for the 2027 financial year.
| Mandate Status | Mandatory |
| Model Type | Clearance |
| Government Entity | Autoridade Tributaria y Aduaneira (AT) |
| Formats | UBL 2.1, CII (Cross Industry Invoice) |
| Infrastructure / Platform | FE-AP (eSPap) central platform and e-invoicing/EDI service provider. |
| E-signature Required | Qualified electronic signature (QES) will become mandatory on PDF e-invoices from 2027. |
| 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 1 January 2027: 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 within EU is allowed if integrity, readability, and accessibility for the Portuguese Tax Authority are ensured. |
Country Situation
Portugal stands at the forefront of digital tax innovation with its comprehensive SAF-T (Standard Audit File for Tax) framework. Developed by the Portuguese Tax and Customs Authority (Autoridade Tributária e Aduaneira), the system is designed to ensure total fiscal transparency.
Centred on the technical standards of Decreto-Lei n.º 28/2019 and Portaria n.º 302/2016, the SAF-T Billing mandate requires all VAT-registered businesses to issue invoices via certified billing software, regardless of how they are exchanged. This approach guarantees the integrity of every transaction through RSA cryptographic hashing, ensuring every document is unique and traceable to a specific series and taxpayer via an ATCUD number and a QR code.
To remain compliant, businesses must register their document series with the Tax Authority to obtain validation codes before issuance. Certified software then generates sequential numbers, applies a digital signature to create an immutable chain of authenticity, and produces compliant PDFs and QR codes. Businesses are legally obligated to report this billing data by submitting a monthly SAF-T (PT) file in XML format by the 5th day of the following month. These technical measures create a verifiable link between taxpayers and the state, with all electronic records subject to a mandatory ten-year retention period.
The SAF-T process is distinct from invoice transmission. While the SAF-T file provides the government with a secure electronic data record, the invoice itself can be delivered in various formats. While structured electronic invoicing is not yet mandatory for all B2B transactions, it is required for B2G (Business-to-Government) entities. Beyond billing, the SAF-T framework also includes specific flows for Working Documents and Stock Movements. A forthcoming mandate for SAF-T Accounting, requiring mandatory reporting for the 2027 fiscal year starting in 2028, will complete Portugal's transition to a fully digitized audit environment.
| Mandate Status | Mandatory |
| Model Type | Clearance |
| Government Entity | Autoridade Tributária e Aduaneira (AT) |
| Formats | Local XML |
| Infrastructure / Platform | Autoridade Tributária e Aduaneira (AT) web portal |
| E-signature Required | HASH generated for each invoice by the certified billing software during the SAF-T Process |
| Key Deadlines | 2007 - Introduction of SAF-T (PT) file structure via Portaria nº321-A/2007\ 2008 - SAF-T mandatory upon request for resident taxpayers using computerized systems\ 2012 - Modernisation of invoicing and linkage to SAF-T via Decreto-Lei nº198/2012\ 2016 - Official Billing SAF-T XML schema established via Portaria nº302/2016\ 2019 - Certified software, ATCUD framework and QR code basis defined via Decreto-Lei nº28/2019\ 1 Jan 2022 - QR code mandatory on invoices\ 1 Jan 2023 - ATCUD mandatory; SAF-T Billing mandatory for non-residents\ 1 Jan 2024 - Deadline becomes 5th of following month |
| AR Mandatory | N/A |
| AP Mandatory | N/A |
| Peppol Available | No |
| Domestic Transactions | All invoices must be issued via a certified billing software, reported through the SAF-T billing process and include ATCUD, hash, and QR code regardless of how they are exchanged. |
| Cross-border Transactions | All invoices must be issued via a certified billing software, reported through the SAF-T billing process and include ATCUD, hash, and QR code regardless of how they are exchanged. |
| Archiving Period | 10 years |
| Archiving Abroad | Archiving within EU is allowed if integrity, readability, and accessibility for the Portuguese Tax Authority are ensured. |
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