Does Portugal require B2B e-invoicing?

No structured B2B e-invoicing mandate exists. However, all invoicing software must be certified by the Portuguese Tax Authority (AT), and monthly SAF-T billing data submissions are mandatory, giving the AT full visibility into all invoicing activity.

The Código Único do Documento is a unique document code required on all invoices in Portugal. It acts as a tamper-proof identifier linking each invoice to the certified software that generated it.

Must all Portuguese invoicing software be certified?

Yes. The AT certifies all invoicing software used in Portugal. Non-certified software is subject to penalties of EUR 3,000 to EUR 18,750.

How long must invoices be retained in Portugal?

10 years per Decree-Law No. 28/2019. Digital archives must ensure accessibility, legibility, and integrity. Offshore storage is permitted if accessible to the AT.

What are the penalties for invoicing non-compliance in Portugal?

EUR 150 to EUR 3,750 per infraction for individuals, and EUR 300 to EUR 7,500 for legal persons. Missing QR codes attract EUR 200 to EUR 1,000 per invoice.

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Portugal e-Invoicing Guide

Key facts, deadlines, and compliance requirements for Portugal's e-invoicing and SAF-T framework.

Model:DecentralisedStandard:EN 16931B2B:None

Updated 2026-03-11

What is e-Invoicing in Portugal?

Portugal combines a B2G e-invoicing mandate with one of Europe's strictest SAF-T (Standard Audit File for Tax) reporting regimes. All invoicing software used in Portugal must be certified by the Portuguese Tax Authority (AT) and must generate SAF-T files for monthly submission.

B2G e-invoicing has been phased in since January 2021 using the CIUS-PT format based on EN 16931. B2B e-invoicing has no current mandate, though the SAF-T requirements mean all invoices are already digitally reported to the tax authority regardless.

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Key Deadlines & Milestones

Portugal's B2G mandate was phased in from January 2021, starting with large contracting authorities and progressively extending to smaller entities. SAF-T reporting has been mandatory since 2008, with monthly submission requirements introduced in 2013. A B2B e-invoicing mandate has not yet been announced.

Jan 2021

B2G mandate for large companiesB2G

Jan 2022

ATCUD and QR Code mandatoryDomestic

Mar 2025

ViDA Package published in Official JournalEU Level

Jan 2026

B2G mandate extends to SMEs/microB2G

Dec 2026

PDF acceptance endsDomestic

Jan 2027

QES mandatoryDomestic

Jan 2027

ViDA: OSS/IOSS ClarificationsEU Level

Jan 2028

Accounting SAF-T deadlineDomestic

Jul 2028

ViDA: Platform Obligations & VAT RegistrationEU Level

Jul 2030

ViDA: Cross-border B2B DRRIntra-EU

Jan 2035

ViDA: Domestic AlignmentDomestic

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Who Needs to Comply?

Government suppliers must submit structured e-invoices in the CIUS-PT format via the national procurement platform. All invoicing software must be certified by the AT and must be capable of generating SAF-T export files.

SAF-T monthly reporting is mandatory for all businesses. This covers all issued invoices, credit notes, and receipts. B2B and B2C transactions do not require structured e-invoicing but are captured through SAF-T reporting. The AT uses this data for automated cross-checking and VAT compliance monitoring.

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How Does It Work?

Portugal uses a decentralised model for B2G e-invoice exchange. Suppliers submit invoices via the FE-AP (Fatura Electrónica na Administração Pública) platform using the CIUS-PT format based on UBL 2.1 or CII.

For all transactions (B2B, B2G, B2C), invoicing software must generate SAF-T files that are submitted monthly to the AT. The tax authority uses this data for pre-filled VAT returns and cross-referencing. The combination of B2G e-invoicing and universal SAF-T gives Portugal strong digital tax visibility without a full B2B e-invoicing mandate.

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What Are the Penalties?

Portugal enforces compliance through fines that vary by entity type: EUR 150 to EUR 3,750 per infraction for individuals, and EUR 300 to EUR 7,500 for legal persons. Using non-certified invoicing software can attract fines of EUR 3,000 to EUR 18,750. B2G non-compliance results in invoice rejection. All invoices must include an ATCUD (unique document code) and QR code for verification.

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