Portugal e-Invoicing Mandate 2027
Post-audit · AT-certified billing software with SAF-T (PT) reporting
E-invoicing is mandatory in Portugal for B2G transactions and has applied to suppliers of every size since 1 January 2026, while B2B e-invoicing remains voluntary in format. All invoices must nevertheless be produced by AT-certified billing software and carry an ATCUD unique document code and a QR code. PDF invoices stay valid without a qualified electronic signature until 31 December 2026.
| Status | Phased |
|---|---|
| Legal basis | Decreto-Lei n.º 123/2018 on B2G electronic invoicing (transposing Directive 2014/55/EU); Decreto-Lei n.º 28/2019 on invoice issuing, archiving and certified software; Portaria n.º 195/2020 introducing ATCUD and the QR code; Lei do Orçamento do Estado para 2026 extending the transitional PDF regime |
| Phase-in | 5 phases, 2021 to 2028 |
| Scope | B2G: Mandatory · B2B: Voluntary · B2C: Voluntary |
| Format | UBL 2.1 CIUS-PT, CII (UN/CEFACT) CIUS-PT, SAF-T (PT) XML · EN 16931 |
| Platform | eSPap FE-AP portal or certified service providers for B2G; SAF-T (PT) billing files submitted to the e-Fatura portal · Post-audit with periodic SAF-T (PT) billing reporting |
| Penalties | Issuing invoices from software that is not certified by the AT is punishable under article 128 of the Regime Geral das Infrações Tributárias with a fine of EUR 1,500 to EUR 18,750 |
Phase-in timeline
2021 to 2028- 2021B2G e-invoicing becomes mandatory for large companies supplying the public sectorlarge enterprises
- 2023ATCUD unique document code and QR code become mandatory on all invoices and fiscally relevant documentsall taxpayers using certified software
- 2026B2G e-invoicing becomes mandatory for small and medium-sized enterprises and micro-enterprises after repeated deferralsSMEs and micro-enterprisesToday
- 2027Qualified electronic signature or seal becomes mandatory for electronic invoices, ending the transitional acceptance of unsigned PDFs
- 2028Submission of the accounting SAF-T (PT) file becomes mandatory, covering financial year 2027
Mandate at a glance
Verified Jul 2026- B2G mandatory
- B2B voluntary
- B2C voluntary
- Non-residents: partially in scope
- UBL 2.1 CIUS-PT
- CII (UN/CEFACT) CIUS-PT
- SAF-T (PT) XML
- EN 16931
- eSPap FE-AP portal or certified service providers for B2G; SAF-T (PT) billing files submitted to the e-Fatura portal
- Periodic reporting (not real-time)
- 10 years
- Digital signature: optional
- Storage: EU
- Issuing invoices from software that is not certified by the AT is punishable under article 128 of the Regime Geral das Infrações Tributárias with a fine of EUR 1,500 to EUR 18,750
- Failing to issue an invoice, or issuing it outside the legal deadline, carries a fine of EUR 150 to EUR 3,750 under article 123 of the RGIT, and failing to communicate invoice data to the AT within the legal deadline carries a fine of EUR 200 to EUR 10,000 under article 117
- An invoice issued without the mandatory ATCUD or QR code is a non-compliant document under the certified-software rules; practitioners report fines of EUR 200 to EUR 3,750 per document under the general RGIT regime
Full technical breakdown: Portugal guide on e-Invoice.app
Is e-invoicing mandatory in Portugal?
Partly. The mandate is being phased in. E-invoicing in Portugal is mandatory for B2G transactions (voluntary for B2C). Portugal operates a post-audit model via eSPap FE-AP portal or certified service providers for B2G; SAF-T (PT) billing files submitted to the e-Fatura portal. Non-resident businesses are partially in scope (see the FAQ below).
What are the Portugal e-invoicing deadlines?
The next Portugal e-invoicing deadline is 1 January 2027: Qualified electronic signature or seal becomes mandatory for electronic invoices, ending the transitional acceptance of unsigned PDFs.
| Date | Scope | Obligation | Threshold |
|---|---|---|---|
B2G | B2G e-invoicing becomes mandatory for large companies supplying the public sector | large enterprises | |
B2G B2B B2C | ATCUD unique document code and QR code become mandatory on all invoices and fiscally relevant documents | all taxpayers using certified software | |
B2G | B2G e-invoicing becomes mandatory for small and medium-sized enterprises and micro-enterprises after repeated deferrals | SMEs and micro-enterprises | |
Upcoming | B2G B2B B2C | Qualified electronic signature or seal becomes mandatory for electronic invoices, ending the transitional acceptance of unsigned PDFs | None |
Upcoming | B2G B2B B2C | Submission of the accounting SAF-T (PT) file becomes mandatory, covering financial year 2027 | None |
What format and platform does Portugal require?
Portugal requires e-invoices in UBL 2.1 CIUS-PT or CII (UN/CEFACT) CIUS-PT or SAF-T (PT) XML (EN 16931), exchanged via eSPap FE-AP portal or certified service providers for B2G; SAF-T (PT) billing files submitted to the e-Fatura portal on a non-real-time basis. Invoices must be retained for 10 years. For format specifications and implementation detail, see the full Portugal technical guide on e-Invoice.app.
What are the penalties in Portugal?
- Issuing invoices from software that is not certified by the AT is punishable under article 128 of the Regime Geral das Infrações Tributárias with a fine of EUR 1,500 to EUR 18,750
- Failing to issue an invoice, or issuing it outside the legal deadline, carries a fine of EUR 150 to EUR 3,750 under article 123 of the RGIT, and failing to communicate invoice data to the AT within the legal deadline carries a fine of EUR 200 to EUR 10,000 under article 117
- An invoice issued without the mandatory ATCUD or QR code is a non-compliant document under the certified-software rules; practitioners report fines of EUR 200 to EUR 3,750 per document under the general RGIT regime
What changed recently?
- B2G e-invoicing became mandatory for small and medium-sized enterprises and micro-enterprises, completing a rollout that had been deferred several times since 2021.
- Parliament approved the 2026 State Budget, which extended the transitional regime again, keeping PDF invoices valid as electronic invoices until 31 December 2026, moving the qualified electronic signature requirement to 1 January 2027 and pushing the accounting SAF-T (PT) obligation to 2028 for financial year 2027.
Need the full Portugal compliance detail?
This page is a high-level snapshot. For registration procedures, technical specifications, exemption rules and implementation guidance, see the detailed Portugal country guide on our partner site e-Invoice.app.
Portugal e-invoicing guide on e-Invoice.appPortugal e-invoicing: frequently asked questions
Are PDF invoices still valid in Portugal in 2026?
Yes. The 2026 State Budget extended the transitional regime once more, so throughout 2026 a PDF invoice is accepted as an electronic invoice without a qualified electronic signature or seal. The invoice must still come from certified software and carry the ATCUD and QR code, and the issuer remains responsible for authenticity, integrity and legibility through business controls. The requirement bites from 1 January 2027.
Do non-resident businesses registered for Portuguese VAT need certified billing software?
In many cases yes. Taxable persons with a Portuguese VAT registration must use AT-certified invoicing software once annual turnover exceeds EUR 50,000 or where they are required to keep organised accounts, and the certification obligation has been progressively extended to non-established taxpayers. Because the position depends on turnover, establishment and the type of supplies made, non-residents should confirm their status with a Portuguese adviser before invoicing.
What is the difference between ATCUD, the QR code and SAF-T (PT)?
ATCUD is a unique document identifier built from a series validation code issued by the AT, the QR code encodes key tax data on the face of the invoice for verification, and SAF-T (PT) is the standard audit file used to report billing data to the AT and, from 2028, accounting data. The full SAF-T schema, series registration workflow and QR code data fields are covered in the detailed Portugal guide on e-Invoice.app.
More detailed questions? See the full Portugal guide on e-Invoice.app.
Sources
This page was verified against the following sources on 23 July 2026.
- RGIT, artigo 128.º (utilização de software não certificado) (Autoridade Tributária e Aduaneira (Portal das Finanças))
- RGIT, artigo 117.º (falta ou atraso de comunicações) (Autoridade Tributária e Aduaneira (Portal das Finanças))
- eInvoicing in Portugal (country factsheet) (European Commission)
- Portugal: postponement of qualified electronic signature requirement and accounting SAF-T approved (Sovos)
- Portugal postpones QES requirements and SAF-T submission (Comarch)
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