E-invoicing in Portugal: deadlines and rules

At a glance

Portugal relies on certified invoicing software, ATCUD, QR code and SAF-T. From 1 January 2027 a PDF counts as an e-invoice only with a qualified electronic signature; the draft 2027 budget would move this to 2028. B2G is mandatory for micro, small and medium suppliers since 2026.

For the VAT status “VAT-registered”.
Size bandReceive sinceIssue from
Micro-enterpriseNo mandate today law Source: Fonoa · undated · verified 15 Oct 2026 · secondary
unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items
Small enterpriseNo mandate today law Source: Fonoa · undated · verified 15 Oct 2026 · secondary
unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items
Medium-sized enterpriseNo mandate today law Source: Fonoa · undated · verified 15 Oct 2026 · secondary
unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items
Large enterpriseNo mandate today law Source: Fonoa · undated · verified 15 Oct 2026 · secondary
unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items

Verified:

Who is affected

Scope: No structured-format receiving obligation was found for domestic B2B

Issuing phases

  • None (all issuers of PDF invoices) law Source: Fonoa · undated · verified 15 Oct 2026 · secondary
    unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items

    A PDF invoice counts as an electronic invoice only with a qualified electronic signature (QES)

    2026 State Budget of 27 Nov 2025. The draft 2027 State Budget (8 Oct 2026) would keep PDF valid to 31 Dec 2027 and move QES to 1 Jan 2028; final vote 24 Nov 2026. No micro or small-business QES carve-out was found.

Small-business regime: Micro and small suppliers (statutory categories)

Must receive e-invoices: no · Must issue e-invoices: yes

Micro and small suppliers are in scope of the B2G mandate since 1 Jan 2026. The QES rule for PDF invoices has no carve-out for them in the sources found.

Model and platform

Hybrid (public platform plus private providers)

Platform: Portal das Finanças (AT) with certified invoicing software, SAF-T (PT) and eSPap for B2G

Invoices are issued by certified software carrying an ATCUD code and a QR code, and are reported to the tax authority through SAF-T (PT). eSPap runs the B2G gateway.

Formats and networks explained

Formats

E-invoice formats in Portugal
FormatSyntaxVersionMust be acceptedNotes
CIUS-PTUBL 2.1 or CIICIUS-PTnoRequired for B2G invoices via eSPap FE-AP or Peppol. Source: ClearTax · undated · verified 15 Oct 2026 · secondary
PDF with qualified electronic signaturePDFQESnoCounts as an e-invoice until 31 Dec 2026 without QES; with QES required from 1 Jan 2027 (move to 2028 proposed). Source: Fonoa · undated · verified 15 Oct 2026 · secondary

Channels and accreditation

Transmission channels in Portugal
ChannelKindRequiredNotes
eSPap FE-APPortalnoPublic-sector invoice gateway (B2G).
PeppolPeppolnoAlternative B2G route.

Vendor accreditation

Registered by the tax authority · Required: yes

Invoicing software must be certified. The certifying body and procedure were not captured in the research. Source: internal research · 15 Oct 2026 · verified 16 Oct 2026 · secondary

unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text.

Receiving: how invoices reach you

Receiving duty: No mandate today none Source: internal research · 15 Oct 2026 · verified 16 Oct 2026 · secondary

unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text.

Certified invoicing software, ATCUD and QR code are already required.

What to set up

  • ATCUD (Every issuer of invoices): Unique document code printed on each invoice, with a QR code.

Sending: what buyers expect

Public sector

Public-sector e-invoicing since law Source: ClearTax · undated · verified 15 Oct 2026 · secondary

unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items

eSPap FE-AP, or Peppol

Formats: CIUS-PT (UBL 2.1 or CII)

Mandatory for micro, small and medium suppliers from 1 Jan 2026 (Decree-Law 13-A/2025). Dates for large suppliers were not captured.

Corporate buyers on SAP Business Network, Coupa, Tungsten or Basware: see Integrations.

Reporting

no date yet law Source: Autoridade Tributária e Aduaneira · undated · verified 15 Oct 2026 · official

unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items

Invoice reporting via SAF-T (PT)

The start date of the existing invoice reporting was not captured. SAF-T for accounting is delayed to 2027 or 2028.

Archiving

Retention period: 10 years Source: Autoridade Tributária e Aduaneira · 27 Mar 2025 · verified 16 Oct 2026 · official

The period starts: The 10 calendar years following the year of the document

  • 10 calendar years: CIVA art. 52 (wording of DL 49/2025, in force 1 Jul 2025) and Código Comercial art. 40.
  • Electronic archiving governed by DL 28/2019 arts. 19-21: storage in Portugal or another EU member state; outside the EU only with prior AT authorisation.

Integration points

  • ATCUD (Every issuer of invoices): Unique document code printed on each invoice, with a QR code.
  • SAF-T (PT) (Every business with certified invoicing software): File-based invoice reporting to the tax authority.
  • eSPap FE-AP (Suppliers to public bodies): B2G gateway; Peppol is the alternative.

Common accounting and invoicing tools

Moloni · InvoiceXpress · TOConline · PHC · Primavera

What this means for you

Generated from the decision rules of our check for four typical profiles. Your answers may differ; run the check for your case.

Check my obligations for Portugal

Deadlines

Show deadlines for
  1. B2G e-invoicing mandatory for micro, small and medium suppliers law Source: ClearTax · undated · verified 15 Oct 2026 · secondary
    Micro, small and medium suppliers to public bodies · public sector, issue
  2. PDF accepted as an e-invoice without QES ends (extension to 2027 proposed in the draft budget) law Source: Fonoa · undated · verified 15 Oct 2026 · secondary
    unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items
    All issuers of PDF invoices · issue
  3. Qualified electronic signature required on PDF e-invoices (move to 2028 proposed) law Source: Fonoa · undated · verified 15 Oct 2026 · secondary
    unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items
    All issuers of PDF invoices · issue
  4. QES required on PDF e-invoices if the 2027 State Budget passes (vote 24 Nov 2026) draft Source: VATupdate · 13 Oct 2026 · verified 15 Oct 2026 · secondary
    unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text. See unverified items
    All issuers of PDF invoices · issue
  5. ViDA: structured e-invoicing and digital reporting for intra-EU B2B supplies; recapitulative statements abolished law Source: European Commission, DG TAXUD · 11 Mar 2025 · verified 15 Oct 2026 · official
    All EU businesses with intra-EU B2B supplies · issue, receive, report · EU

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Sources

  1. CIVA artigo 52.º — prazo de arquivo e conservação · Autoridade Tributária e Aduaneira · 27 Mar 2025 · verified 16 Oct 2026 · official
  2. E-invoicing in Portugal · ClearTax · undated · verified 15 Oct 2026 · secondary
  3. Portugal: QES e-invoice delay · Fonoa · undated · verified 15 Oct 2026 · secondary
  4. Portugal proposes another delay for PDF e-invoices to January 2028 · VATupdate · 13 Oct 2026 · verified 15 Oct 2026 · secondary
  5. E-invoicing legislation research, status as of 15 October 2026 (internal evidence log) · einvoice project · 15 Oct 2026 · verified 16 Oct 2026 · secondary · internal document docs/research/einvoicing-legislation-2026-10.md
  6. Adoption of the VAT in the Digital Age package · European Commission, DG TAXUD · 11 Mar 2025 · verified 15 Oct 2026 · official
  7. Portal das Finanças (domain only; deep link not captured) · Autoridade Tributária e Aduaneira · undated · verified 15 Oct 2026 · official

Unverified items

We found this in secondary sources or sources disagree; we have not yet confirmed it in the official text.

  • Draft 2027 State Budget (8 Oct 2026) would keep PDF valid to 31 Dec 2027 and move QES to 1 Jan 2028; final vote 24 Nov 2026.
  • SAF-T accounting is delayed to 2027 or 2028; the exact date was not found.
  • No QES carve-out for micro or small businesses was found.
  • B2G dates for large suppliers, penalties, the certifying body for invoicing software and the start of SAF-T invoice reporting are not covered by the research.
  • Whether a structured-format mandate for domestic B2B exists was not found; PT is shown as scheduled only because of the QES rule for PDF invoices.
  • Deep links on portaldasfinancas.gov.pt and espap.gov.pt were not captured; only the domain of the former is recorded as a source.

4 logged changes for Portugal