Send Invoice in Portugal

In Portugal, invoicing is governed by a robust legal framework designed to enhance tax administration and combat evasion, primarily rooted in the Portuguese VAT Law (Código do Imposto sobre o Valor Acrescentado – CIVA) and Decreto-Lei n.º 28/2019. Article 36 of CIVA mandates that an invoice must be issued for all supplies of goods and services, including exports and intra-Community supplies, as well as any advance payments. The legal framework ensures that electronic invoices hold the same legal status as paper invoices, provided they meet authenticity and integrity requirements.

To be compliant, invoices must contain specific mandatory information. This includes your company's name, address, and Taxpayer Identification Number (NIF), along with the same details for your customer. Crucially, each invoice needs a unique invoice number, the issuance date, payment due date, a detailed description of goods or services, the total amount due, and applicable VAT rates. Furthermore, all invoices, whether paper or electronic, must include a unique document code (ATCUD) and a QR code, generated by AT-certified software, to ensure traceability and authenticity.

Non-compliance with these regulations can lead to significant penalties. For instance, failing to issue a legally compliant invoice, or issuing one that lacks required information, can result in fines ranging from €150 up to €3,750 per infraction. Using non-certified billing software can incur even steeper fines, from approximately €3,000 up to €18,750. Additionally, late or missing SAF-T (Standard Audit File for Tax) submissions can also trigger penalties.

Electronic invoicing, or e-invoicing, in Portugal refers to the issuance, transmission, receipt, and storage of invoices in a structured electronic data format, allowing for automatic electronic processing. This digital shift offers several compelling benefits for businesses, including enhanced compliance with Portuguese tax regulations, significant cost savings on printing and storage, and faster processing of invoices, leading to quicker verification, approval, and payment. E-invoicing also improves security by minimizing fraud risk through features like Qualified Electronic Signatures (QES) and AT-certified applications, while facilitating auditing and tax reporting with SAF-T files.

While B2B (Business-to-Business) and B2C (Business-to-Consumer) e-invoicing is not yet universally mandatory in Portugal, all VAT-registered businesses must electronically transmit invoice data to the tax authority (AT) for all transactions, even if the invoice itself is a paper or PDF document. This is achieved through certified invoicing software that assigns an ATCUD and QR code to each invoice and reports details via SAF-T files. For B2G (Business-to-Government) transactions, e-invoicing in a structured electronic format is mandatory for all suppliers to the public sector.

Implementing e-invoicing involves a clear workflow:

• Utilize AT-certified software: All invoices must be generated using software certified by the Portuguese Tax Authority (AT).
• Ensure correct format: For B2G transactions, invoices must be in the CIUS-PT format (UBL 2.1 or CEFACT), which is compliant with the European e-invoice standard EN16931.
• Include mandatory details: Ensure all required information, such as the ATCUD (Unique Document Code) and QR code, is present.
• Apply Qualified Electronic Signature (QES): While simple PDFs are accepted as electronic invoices for B2B/B2C until December 31, 2026, a QES will be mandatory for all non-EDI electronic invoices, including PDFs, from January 1, 2027, to ensure legal validity and integrity.
• Transmit invoices: For B2G, invoices are typically sent through the government's FE-AP platform. For B2B, various channels providing an end-to-end SAF-T audit functionality are acceptable.

A Qualified Electronic Signature (QES) is a crucial element in Portugal's digital invoicing landscape, serving as a highly secure digital signature that confirms the authenticity and integrity of an electronic document. It is created by a private, accredited entity and is legally recognized for verifying the identity of the company issuing a signed document. This ensures that the electronic invoice remains unchanged after issuance and that the issuer can be clearly identified, providing a robust layer of security and trust in digital transactions.

While the search results do not detail the exact steps to obtain a QES, it is generally acquired from a certified trust service provider that is accredited to issue such signatures in compliance with EU regulations (eIDAS Regulation). Businesses need to engage with these providers to go through an identity verification process and receive the necessary digital certificate.

The importance of electronic signatures in compliance cannot be overstated. For B2G e-invoices, a digital signature has been a mandatory requirement to ensure authenticity. Looking ahead, starting January 1, 2027, all PDF invoices, including those for B2B and B2C transactions, will need to include a Qualified Electronic Signature (QES) to be considered legally valid electronic documents. This upcoming mandate underscores the critical role QES will play in ensuring the legal validity and integrity of virtually all electronic invoices in Portugal.

In Portugal, Business-to-Government (B2G) invoicing has specific and mandatory requirements, reflecting the country's commitment to digitalizing public procurement. Since January 1, 2024, all suppliers to the Portuguese public sector, including Small and Medium-sized Enterprises (SMEs) and micro-enterprises, are required to issue e-invoices in a structured electronic format. Large companies have been subject to this mandate since January 2021. Public administrations, in turn, have been obligated to receive and process e-invoices since April 2019.

The accepted formats for B2G e-invoices are CIUS-PT (XML), CEFACT CIUS-PT, or Peppol BIS 3.0. The CIUS-PT is Portugal's national adaptation of the European Standard EN 16931, ensuring interoperability across EU systems. These XML-based formats are crucial for machine readability and automated processing. The Peppol network plays a significant role in B2G invoicing, with eSPap (Entidade de Serviços Partilhados da Administração Pública), the Portuguese public sector shared services entity, acting as a Peppol Authority. This means suppliers can leverage a Peppol Access Point to transmit invoices to government entities.

Submission processes for government invoices typically involve the government's centralized FE-AP platform, managed by eSPap. Suppliers can send invoices via WebServices or AS2 protocols after a registration process with eSPap. For businesses issuing fewer than 250 invoices annually, a manual upload option via the FE-AP Microportal is available. It's important for suppliers to verify specific transmission requirements with individual public entities, as some may use third-party portals or direct EDI connections.

Portugal's invoicing landscape is continuously evolving, with several significant regulatory changes on the horizon that businesses should prepare for. A key upcoming change is the mandatory requirement for a Qualified Electronic Signature (QES) on all PDF invoices. While simple PDF invoices are currently accepted as electronic invoices for B2B and B2C transactions until December 31, 2026, this will change from January 1, 2027, when a QES will become essential for their legal validity. This move aims to further enhance the security, reliability, and trustworthiness of digital invoices.

Another important development is the mandatory submission of the SAF-T (Standard Audit File for Tax) Accounting file. While monthly SAF-T Invoicing (SAF-T PT) submissions are already required by the 5th day of the following month for sales invoices, transport documents, and cash receipts, the full SAF-T Accounting file will become mandatory for the 2027 fiscal year, with the actual submission due in 2028. This will provide the tax authority with more comprehensive financial records, facilitating audits and improving transparency.

These changes will particularly impact Small and Medium-sized Enterprises (SMEs). While large companies have already been subject to B2G e-invoicing mandates since 2021, SMEs and micro-enterprises are required to comply with B2G e-invoicing from January 1, 2026. Portugal is also actively aligning its systems with the EU's "VAT in the Digital Age" (ViDA) initiative, which anticipates further reforms to e-invoicing and e-reporting frameworks by 2028–2030, aiming for near-real-time digital reporting.

To adapt to these upcoming regulations, businesses should:

• Invest in certified invoicing software: Ensure your software is up-to-date and capable of generating invoices with ATCUD, QR codes, and Qualified Electronic Signatures.
• Plan for QES implementation: Begin the process of obtaining and integrating Qualified Electronic Signatures into your invoicing workflow well before the January 1, 2027 deadline.
• Prepare for SAF-T Accounting: Understand the requirements for the full SAF-T Accounting file and ensure your accounting systems can generate this data for the 2027 fiscal year.
• Stay informed: Continuously monitor updates from the Autoridade Tributária e Aduaneira (AT) and eSPap to remain compliant with evolving mandates.