E-invoicing in Portugal & Digital Reporting Requirements

What is electronic invoicing in Portugal?

Portugal is implementing a new law that requires all B2G (business-to-government) transactions to be conducted with electronic invoices, which are specific, highly regulated digital documents that comply with specific, highly regulated technology.

Some of the goals of e-invoicing in Portugal are to:

• Streamline and automate financial reporting
• Make payments more punctual and efficient
• Increase the government recoup of VAT revenue

These goals and the plan for electronic invoicing in Portugal stem from the European Union's VAT in the Digital Age (ViDA) plan, which wants to see e-invoicing and digital reporting spread across Europe.

Electronic invoicing in Portugal will come into effect on January 1, 2025 for businesses that are selling to public entities. In the future, these e-invoicing rules might apply to all businesses and all types of transactions.

For now, other electronic data submission and reporting requirements, such as using qualified electronic signatures (QES) will affect all businesses and all sales, including B2B and B2C. These rules come into effect on January 1, 2025.

The e-invoicing rules were drafted in several decrees throughout 2017-2021, and iterated on even more after that. You can check out the official law here.

In fact, electronic invoicing is rolling out in most countries around the world, including other EU member states. For example, Spain e-invoicing rules and France e-invoicing rules are in the works.

Important: PDF invoices will be considered as electronic invoices for all tax related purposes until December 31, 2024. But after that, the real e-invoicing rules apply and PDFs are no longer valid.

Who is required to issue electronic invoices in Portugal?

Large businesses that make B2G transactions are all required to issue electronic invoices in Portugal and comply with the digital reporting requirements.

Large businesses are defined as those that employ more than 250 people or have an annual turnover of more than €50 million or have an annual balance sheet total of more than €43 million.

As of January 2025, these rules apply to everyone else selling B2G. So micro, small, and medium-sized companies must also send e-invoices for transactions to public authorities.

B2B and B2C transactions are not included in the e-invoicing rules, and there is currently no timeline for this implementation. For businesses selling B2B and B2C, electronic invoicing in Portugal is optional.

How does Portuguese e-invoicing work?

There are a few different actors involved in the Portuguese e-invoicing process, and each one has a specific role:

1. Portugal’s Ministry of Finance is the governmental body responsible for overseeing the e-invoicing project.
2. The Public Administration Shared Services Entity IP (ESPAP, IP), is the entity that coordinates the implementation of electronic invoicing. The ESPAP, IP has created a solution for public administrations to issue electronic invoices, in accordance with EU standards. That solution is…
3. The Electronic Invoice Portal for Public Administration, or FE-AP, is the government’s technology portal for receiving and processing electronic invoices.
4. Private platforms for electronic invoicing, which must comply with the criteria for iAP, Interoperabilidade na Administração Pública.
5. The businesses that send the electronic invoices.
6. The public entities that receive the electronic invoices.

The FE-AP portal offers the ability to receive invoices and correct documents in an electronic format, ensuring security and oversight at all stages of the process. The portal is available to any public entity and offers direct integration with Portugal’s GeRFiP accounting solution, as well as with other web services or third-party accounting or invoice management systems.

So, business owners that need to produce e-invoices can either use the publicly provided solution or a third-party private software that is designed to automatically handle electronic invoices on their behalf. These systems, the public and the private, are compatible and can “communicate” with each other, so to speak.

But aside from the basic steps of the process, there are a number of obligations on both the companies that send and receive invoices and the providers that offer electronic invoicing services.

Rules for complying with Portuguese e-invoicing

The law outlines numerous obligations, and we can’t list them all here. But this list contains many of the rules that are important for onlines businesses:

• Businesses and public entities are obliged to issue, send, and receive electronic invoices through private platforms or the FE-AP public solution offered by ESPAP, IP.
• Private e-invoicing providers will have to ensure free interconnection and interoperability between technology solutions or platforms.
• The sender and recipient need to provide information on the status of invoices via digital reporting.
• E-invoices must be stored in a secure archive by both the issuer and recipient for 10 years.

Penalties for not complying with electronic invoicing in Portugal

Mistakes that result in not complying with electronic invoicing in Portugal range from late reporting to faulty bookkeeping. Each mistake comes with a potentially hefty fee.

• Missed deadline when issuing invoices or receipts: €150-€3,750
• Transaction or use of billing software or equipment that doesn’t comply with legally required documents: €3000-€18,750
• Inaccuracies or missing data in statements or tax-relevant documents: €750-€22,500

So, make sure you are tracking deadlines, using a compliant invoicing software, and following the appropriate accounting practices! If you’re located in Portugal, you should probably be following the accounting rules of the International Financial Reporting Standards (IFRS).

How to create an electronic invoice in Portugal

The Portugal e-invoicing decree lays out several technical specifications that all businesses must adhere to, in order for an e-invoice to function, travel through the system, and be registered as legitimate.

First, electronic invoices in Portugal must be formatted in ways that are compatible with the FE-AP portal used by government as well as private providers. So, the e-invoices must be generated using one of the following formats:

• UBL (Universal Business Language). An XML format for invoices and credit notes that must adhere to the CIUS-PT specifications. Portugal offers a free compatibility check here.
• CEFACT (Cross Industry Invoice). An XML format that contains a maximum data-set for specific use cases. It must also comply with CIUS-PT.

As of January 1, 2025, a qualified electronic signature (QES) is mandatory on each e-invoice.

How to send an e-invoice in Portugal

1. Make sure that the e-invoice is in a proper format, such as UBL 2.1 “CIUS-PT” or CEFACT “CIUS-PT” mentioned above.
2. Establish a connection with a third-party e-invoicing provider in order to comply with requirements.
3. Connect to the FE-AP portal.
4. Transfer the e-invoice via the e-invoicing service provider.

What are the digital reporting requirements for e-invoices in Portugal?

Digital reporting is an important part of the Portuguese e-invoicing requirements. Taxable persons (both resident and non-resident) with an annual turnover above €50,000 must use invoicing software certified by the Portuguese tax authority to send invoice data to the Autoridade Tributária platform.

Once a business surpasses that annual turnover threshold, it must fulfill these other reporting obligations:

1. Electronic transmission of invoice data using one of these 3 methods:
   1. Transmitting documents and data in real-time, via web service or third-party
   2. Sending a SAFT-PT invoicing file, once a month
   3. Manually uploading the XML file on the tax authority portal
2. Ability to create and export a SAFT-PT accounting file when the tax authority requests it. From 2025, this file should be exported and submitted to the tax authority annually. So, to report on the fiscal year of 2025, the mandatory submission should be made in April 2026.
3. Electronic submission of data related to shipping documents.

Monthly reporting should be done by the 5th day of the following month.

What is a SAFT-PT?

The Standard Audit File for Tax Purposes - Portuguese version (SAFT-PT) is a standardized XML file used for exporting the accounting information of a company to the tax authorities. SAFT-PT complies with the Portuguese law of a directive from the Organization for Economic Co-operation and Development (OECD).

The SAFT-PT invoicing files are created and submitted monthly. The SAFT-PT accounting files are created either upon request, or – as of 2025 – created and submitted once a year.

Types of transaction documents required in Portugal digital reporting

Several different types of invoices and other transaction documents could be required when reporting tax and sales data to the Portuguese government. These include:

• Invoices
• Simplified invoices
• Receipt
• Invoice-Receipt
• Credit notes (full and partial)

At Quaderno we are already working to support the future law in Portugal, so we can serve our customers with Portuguese e-invoices as soon as it’s required. For now, our automatic invoices and VAT compliance help business owners save time and have peace of mind. See the benefits with Quaderno’s free trial.