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Portugal E-invoicing

Portugal, like every other country, is on a unique e-invoicing journey. While it was early in adopting digital reporting requirements, the country still has a way to go before electronic invoicing is fully mandated.

This page provides an ideal overview of Portugal e-invoicing. Be sure to bookmark it to stay ahead of future mandate changes.

B2B e-invoicing in Portugal

In Portugal, issuing and receiving electronic invoices for B2B transactions is not mandatory. However, an organisation may voluntarily issue an e-invoice to a buyer upon the buyer’s acceptance.

Some believe that Portugal will not enforce B2B e-invoicing as it has introduced other means of monitoring VAT among private entities – namely ATCUD codes, SAF-T for invoicing and, as of 2027, SAF-T accounting.

B2G e-invoicing in Portugal

The Portuguese government has been working on introducing mandatory electronic invoicing for B2G transactions in recent years.

The mandate’s implementation has been gradual. It began with the mandatory receipt of electronic invoices by the public administrations in April 2019, followed by a phased introduction of mandated issuance of e-invoices for suppliers of the public administration – starting with large companies in January 2021. Currently, only large companies are required to issue invoices electronically.

In Portugal, Law Decree 111-B/2017 and subsequent amendments established the beginning of the obligation to issue, receive and process electronic invoices in public procurement. ESPAP (Entidade de Serviços Partilhados da Administração Pública) is the Portuguese entity responsible for the implementation and management of B2G e-invoicing.

Learn more about B2G e-invoicing in Portugal.

The use of Peppol in Portugal

Portugal’s tax authority utilises the e-invoicing framework and network Peppol for its B2G e-invoicing initiative.

The mandate requires e-invoices to be formatted in a specific way and include set information. Peppol provides a standardised electronic invoice format called Peppol BIS Billing 3.0 that the Portuguese tax authority accepts. Suppliers must use certified invoicing software that supports Peppol (or another accepted e-invoicing standard).

The Government Shared Services Entity (eSPap) is Portugal’s Peppol Authority.

Find out more about Peppol e-invoicing.

Timeline of e-invoicing adoption in Portugal

The following dates mark significant milestones in Portugal’s e-invoicing journey.

  • January 2013: Resident taxpayers must send invoice data to the Portuguese tax administration
  • 31 August 2017: The law governing the country’s e-invoicing system was passed
  • 7 April 2020: The government adopts exceptional measures to ease the adoption of e-invoicing, establishing deadlines for the B2G mandate
  • 1 January 2021: Large companies must issue e-invoices to the public administration
  • 27 June 2022: Portugal publishes the 2022 Budget Law, which introduces significant changes to digital reporting obligations
  • 1 January 2024: Small, medium and micro companies must issue e-invoices to the public administration
  • 1 January 2026: Electronic invoices must be secured with a Qualified Electronic Signature (QES) to guarantee their validity

Setting up e-invoicing in Portugal with Sovos

Portugal’s e-invoicing regime is unique, just like that of every other country. It can be hard to meet specific demands, especially when operating in Portugal and other countries at the same time.

Sovos serves as a single compliance partner wherever you do business, ensuring you meet your e-invoicing and tax obligations without sacrificing time, effort or peace of mind. Contact us today to learn more about how our expert team can help your organisation.

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FAQ

E-invoicing is mandatory for B2G transactions in Portugal, but it is voluntary for B2B. Buyer acceptance is required before e-invoices are issued.

e-Fatura is the online portal of the Portuguese Tax and Customs Authority (AT) that collects and stores invoice data reported through certified billing software. Taxpayers should monitor e-Fatura as it enables tax deduction claims and makes tax filing simpler.

The use of certified billing software is mandatory for the creation of all types of invoices (paper or electronic); this is understood to be the taxpayer’s ERP system.

Since 2021, non-resident companies with a Portuguese VAT registration have also become obligated to issue invoices and other fiscally relevant documents via certified billing software.

Since 1 January 2023, all invoices and fiscally relevant documents must include both a QR code and a unique ID number (ATCUD).

The unique document code (ATCUD) allows a document to be uniquely identified, regardless of its issuer, document type, or series used.

E-invoices must be issued electronically in the CIUS-PT format and transmitted to the public administration through approved channels.

Yes. In Portugal, billing SAF-T has monthly submission requirements and must be completed with the normal VAT return by the 5th day of the month following the reporting period. The Billing SAF-T may be submitted via the e-Fatura portal or web services.

The obligatory submission deadline for the accounting SAF-T file was postponed to 2027 pertaining to the financial year of 2026.

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