PEPPOL IN EUROPE
E-invoicing in Portugal
Electronic invoicing in Portugal is currently mandatory for B2G transactions but remains optional for B2B transactions.
In B2G, e-invoicing became mandatory for large enterprises in 2022. As of January 2023, this obligation has also applied to medium-sized, small, and micro-companies.
- Large enterprises: More than 250 employees, annual sales over EUR 50 million, balance sheet total of EUR 43 million.
- Medium -sized companies: Fewer than 250 employees, annual sales no more than EUR 50 million, balance sheet total no more than EUR 43 million.
- Micro-companies: Fewer than 10 employees, annual sales or balance sheet total no more than EUR 2 million.
For receiving electronic invoices in B2G, the eSPap platform (Entidade de Serviços Partilhados da Administração Públicad) was developed by the relevant public authority. Compliance with the UBL 2.1 CIUS-PT or CEFACT CIUS-PT standards is required.
Electronic invoicing in the B2B sector is still optional in Portugal. While the Portuguese government has indicated plans to introduce an e-invoicing obligation, no official statement has been released.
Despite several postponements, invoices in PDF format are still accepted as electronic invoices for all tax purposes in Portugal. However, since January 1, 2023, every PDF invoice must include a digital signature to be considered valid. For instance, all invoices have to contain a QR code and a unique ID, the ATCUD, which is additionally required for all invoices and tax documents. A component of this ID is a validation code that needs to be obtained from the tax authority and is valid for at least a fiscal year. From January 1, 2026, PDF invoices must also include a Qualified Electronic Signature or a Qualified Electronic Seal, issued to taxpayers by certified third-party providers.
