Portugal’s VAT Regime

Portugal pushes further ahead with VAT digitization

Back in 2019, Portugal passed a mini e-invoicing reform consolidating the country’s framework around SAF-T reporting and certified billing software.

Since then, a lot has happened: non-resident companies were brought into the scope of e-invoicing requirements, deadlines were postponed due to Covid, and new regulations have been published.

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Quick facts

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 been obligated to issue invoices and other fiscally relevant documents via certified billing software.
A QR code should be included in all invoices issued through certified billing software. Technical specifications about the content and placement of the code in the invoice are available on the tax authority’s website.
A unique ID number (ATCUD) must be included in all invoices and fiscally relevant documents. The ATCUD is a number with the following format ‘ATCUD:Validation Code-Sequential number’.
Public entities must receive e-invoices whilst companies must send e-invoices since 1 July 2021. E-invoices must be issued electronically in the CIUS-PT format and transmitted to the public administration through one of the available web services.
A qualified electronic signature or seal, or the use of EDI with contracted security measures is mandatory for all electronic invoices from 1 January 2026.
Billing SAF-T has monthly submission requirements and must be completed with the normal VAT return by the 5^th (until the 8th during the year of 2023 due to a grace period) day of the month following the reporting period. The Billing SAF-T may be submitted via the e-fatura portal or through web services.
Accounting SAF-T: annual submission is mandatory from 2027 via the tax authority´s portal which will enable automatic pre-filling of the VAT IES´ Annexes.

Important dates

1 July 2021: Non-resident taxpayers required to use a certified billing software to issue invoices and other fiscally relevant documents.
Issuance of B2G e-invoices:
1 January 2021: Phased rollout of mandatory issuance of e-invoices in the CIUS-PT format for large suppliers of the public administration.
1 January 2022: QR code requirement implemented for invoices and other fiscally relevant documents issued through a certified billing software.
1 January 2023: Unique ID number (ATCUD) is mandatory on all paper and electronic invoices.
1 January 2023: Non-resident taxpayers required to submit Billing SAF-T monthly.
2026 fiscal year: Mandatory annual submission of accounting SAF-T for residents and non-residents (first submission occurs in 2027 regarding the fiscal year of 2026)
1 January 2025: Mandatory B2G E-invoicing extended to include small and medium-sized businesses.
1 January 2026: Qualified electronic signature/seal or EDI mandatory for electronic invoices.

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