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Portugal's e-invoicing regulation timeline

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Executive summary

Portugal mandates electronic invoicing for all B2B transactions starting January 1, 2026, through the ATCUD/QR system. This regulation requires businesses to use approved software that generates invoices with unique validation codes (ATCUD) assigned by the Portuguese Tax Authority (AT), ensuring transparency and preventing fraud. Each invoice must include a QR code that links to the AT’s online verification service, allowing customers and tax authorities to validate invoice authenticity. Invocing in Portugal is based on the EN 16931 standard with CUIS extensions, requiring businesses to notify the AT of their numbering series before issuance. The AT then validates and issues unique codes for each series, creating a centralized tracking mechanism for all invoices. Portugal also requires SAF-T (Standard Audit File for Tax) reporting, an XML-based format used to submit accounting and invoicing data to tax authorities. This system enables standardized digital audits and tax compliance, with mandatory reporting for B2G and B2B transactions from January 1, 2024. This article provides comprehensive guidance on ATCUD/QR invoicing requirements, SAF-T reporting, and Portuguese invoicing regulations. Invopop provides comprehensive coverage for Portuguese invoicing through dedicated apps for AT Portugal and InvoiceXpress Portugal, as well as integrations with platforms like Stripe and Chargebee. This allows businesses to issue compliant ATCUD invoices efficiently and manage white-label (B2B2B) operations.

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Invoicing in Portugal

Portugal does not mandate a specific electronic invoice format. Instead, businesses report tax information to the Portuguese Tax Authority (AT - Autoridade Tributária e Aduaneira) either periodically through SAF-T (PT) reports or in real time via web service.
Although no format is required, all invoices must include ATCUD and a QR code.
  1. ATCUD (Unique Code):
    • Businesses must register their invoice numbering series with the AT
    • The AT issues a validation code for each registered series
    • This code must appear on each invoice
  2. QR Code:
    • All invoices must contain a QR code
    • The QR code links to the AT’s online verification service
ModelsB2B, B2C
FormatUnspecified (paper or PDF used in practice)
InfrastructureHybrid: public and private platforms
ModelCentralized
Scope & DeadlineAll B2B invoices from Jan 1, 2026
AgencyAT Portugal
Invopop SupportAT Portugal App
InvoiceXpress Portugal App (deprecated)
https://assets.invopop.com/apps/at-pt/icon.svg

AT Portugal

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CUIS-PT is a XML-based invoice format used for B2G transactions.
ModelsB2G
FormatCUIS-PT (XML)
InfrastructureBASE
Scope & DeadlineMandatory for B2G invoices from Jan 1, 2024
AgencyAT Portugal
Invopop SupportNo

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E-reporting

The SAF-T (Standard Audit File for Tax) system was introduced in Portugal in 2008 to facilitate the electronic submission of VAT returns, accounting records, and transport documents. This system requires files to be generated in specific formats containing detailed information regarding commercial transactions. Taxpayers with headquarters, based or permanently established in Portugal, subject to corporate tax (IRC) or income tax (IRS) that keep organized accounting, must comply with this system.
SAF-T (Standard Audit File for Tax) is an XML-based file format used to report accounting and invoicing data to the tax authority, enabling standardized digital audits and tax compliance.
FormatSAF-T PT (XML)
Scope & deadlineB2G and B2B from 1 Jan 2024
Invopop supportYes
https://assets.invopop.com/apps/at-pt/icon.svg

AT Portugal

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Regulation

According to Article 36(5) of the Código do IVA, all invoices must be dated, sequentially numbered, and contain the following:Standard invoice
  • Supplier identification: name or business name, registered address, and NIF (Número de Identificação Fiscal).
  • Customer identification: name or business name, address, and NIF of the customer when the customer is a taxable person. For non-taxable individuals (final consumers), the NIF is only required when the customer requests it.
  • Goods or services description: quantity and usual denomination, with enough detail to determine the applicable tax rate. Non-invoiced packaging must be listed separately with an express mention of its agreed return.
  • Unit price: price net of tax and any other elements included in the taxable value, along with any discounts or rebates not already reflected in the unit price.
  • Applicable VAT rate(s) and the corresponding tax amount(s). When a single invoice covers items subject to different VAT rates, the description, price, and tax must be broken down separately for each rate.
  • Exemption justification: if VAT does not apply, the invoice must state the legal basis for the exemption (for example, “IVA – regime de isenção” for Article 53 small-business exemptions).
  • Date of supply: the date goods were delivered or services were performed, if different from the invoice issue date. Also required when advance payments are received before the operation is complete.
  • ATCUD: the document unique code assigned through series registration with the AT.
  • QR code: linking to the AT’s online verification service.
Invoices must be issued no later than the fifth business day following the date when VAT becomes due. For certain intra-EU service provisions, the deadline extends to the 15th day of the following month.Simplified invoice (fatura simplificada)Under Article 40 of the Código do IVA, simplified invoices may be issued for:
  • Retail sales to final consumers up to €1,000
  • Other supplies of goods or services up to €100
A simplified invoice must contain:
  • Supplier name or business name and NIF.
  • Goods or services description and quantities.
  • Price: either the net price plus VAT amount and rate, or the total price with VAT included and the applicable rate.
  • Customer NIF: mandatory only when the customer is a taxable person (B2B). For final consumers, it is included only if the customer requests it.
  • Exemption justification, if applicable.
  • Sequential number and date of issue.
Decreto-Lei 28/2019 governs invoice processing obligations in Portugal, including numbering rules and the ATCUD system.Numbering rules
  • Invoices must be issued within one or more series, dated and numbered sequentially and continuously.
  • Each series must run for at least one fiscal year.
  • The series identifier must be unique per establishment and/or software program, and cannot be reused for the same document type by the same taxpayer.
  • Separate series are required for different document types (invoices, credit notes, receipts, and so on).
Series registrationBefore issuing invoices, businesses must communicate each documentary series to the AT through the e-fatura portal. The communication must include:
  • The series identifier
  • The document type
  • The starting sequential number
  • The expected date the series will begin use
ATCUD compositionThe AT assigns a validation code (minimum eight characters) for each registered series. The ATCUD is formed by concatenating:
  1. The series validation code
  2. A hyphen
  3. The sequential document number
The ATCUD must appear on the invoice in the format: ATCUD:XXXXXXXX-NNNNNNNN.
All businesses in Portugal must use invoicing software certified by the AT. Decreto-Lei 28/2019 establishes that:
  • Software must be registered and approved by the AT before use.
  • Each invoice must include a digital signature hash generated by the certified software, creating a chain of integrity across documents.
  • The software must support the generation of ATCUD codes and QR codes on all tax-relevant documents.
  • Businesses using the AT’s free online invoicing portal are also considered compliant.
When the customer issues an invoice on behalf of the supplier, Article 36(11) of the Código do IVA requires a prior written agreement between the parties. The agreement must include:
  • Full identification of both parties (name, NIF, address)
  • An express statement that the customer will issue invoices on the supplier’s behalf
  • A description of the covered operations
  • Express acceptance by the supplier
  • Period of validity and revocation conditions
  • Signatures of both parties
The agreement must be communicated to the AT through the e-fatura portal and retained for ten years.
eInvoicing for public procurement is managed through BASE, a central platform that provides solutions like acinGov and saphetygov for electronic invoicing. While the FE-AP platform can be used to receive invoices, its use is not mandatory, leading to various methods for sending invoices, including web-based services, direct electronic connections, third-party portals, or email.
Business owners must keep transaction records for ten years. If the tax settlement period is longer than ten years, records must be maintained until the end of the settlement period.More information can be found on the Tax and Customs Authority PDF (in Portuguese).
  1. VAT
  • General rate: 23%
    • PT-AC: 16%
    • PT-MA: 22%
  • Intermediate rate: 13%
    • PT-AC: 9%
    • PT-MA: 12%
  • Reduced rate: 6%
    • PT-AC: 4%
    • PT-MA: 4%
Read more about taxation in Portugal.
Under Article 39 of the Código do IVA, invoice issuance is waived when all of the following conditions are met: the customer is a private individual not using the goods or services for commercial, industrial, or professional activity, and the transaction is paid in cash.The exemption applies to:
  • Retail sales by retailers or street vendors.
  • Sales through vending machines.
  • Services where access is via a numbered receipt, admission ticket, transport ticket, or other printed bearer document proving payment.
  • Other service provisions valued under €10.
Even when exempt, retailers and service providers must still issue an invoice when:
  • The customer is a VAT-taxable person.
  • A non-taxable customer requests one.
Exempt businesses must still issue pre-numbered sales receipts or use electronic cash registers that document all operations.
Refer to the QR code technical specification published by the Autoridade Tributária (AT).When using our “Generate PDF” action, Invopop complies with the requirements by the AT in producing PDF invoices with the QR code.

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