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Compliance questions

All invoices issued in Portugal must include a unique sequential number, a series identifier, an ATCUD code (Article 35-A CIVA), and a QR code (Portaria 195/2020). Software must be certified by the Autoridade Tributária — Invopop is certified.
Any entity with a Portuguese NIF — companies, sole traders, and freelancers. NIFs starting with 1, 2, or 3 are individuals (autónomos); NIFs starting with 5 are legal entities, which require additional registration metadata (share capital, commercial registry).
Monthly or quarterly IVA periódica plus the annual IES (Informação Empresarial Simplificada). Invoice-level data is reported continuously through real-time submission or monthly SAF-T export — both feed AT’s e-fatura system automatically.
Supplier registration information includes the company’s share capital, the commercial registry office, and optionally the NIF used during registration. Portuguese law requires this information to appear on all printed fiscal documents, including PDFs.When is it mandatory?Registration information is mandatory for companies and legal entities. However, self-employed individuals and freelancers (whose NIF starts with 1, 2, or 3) are exempt from this requirement, as they typically do not have formal registration details.What about the “other” field?The other field is optional and can be used to specify the NIF of the company when it was registered if different from the current one.
The supplier must use certified billing software, register their issuance series with AT, and choose a reporting model (monthly SAF-T or real-time). Self-employed taxpayers (NIF starting 1/2/3) are exempt from supplier registration metadata; companies must declare share capital and commercial registry.
Either real-time per-invoice transmission or monthly SAF-T export by the 5th of the following month. Both satisfy the reporting obligation under Portaria 195/2020 — the choice is operational.

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Invoicing questions

In Portugal, fiscally relevant documents issued through invoicing software must be reported to the Tax Authority (AT). There are two possible reporting models:
  1. SAF-T monthly export – a single XML file including all documents for the month. This file is generated by the invoicing software and then uploaded manually to the AT portal, as there is no API available for submitting it automatically.
  2. Real-time transmission – instead of a monthly file, each invoice is sent individually to the AT at the time of issuance, using the authority’s API.
Whether one model or the other is used usually depends on the issuer’s accountant’s preference (who typically uploads the SAF-T monthly report should they choose that model). Invopop’s AT Portugal app supports both reporting methods, so each supplier can pick the one that best fits their needs.If a supplier uses real-time transmission — the Send document to AT step in the workflow — the documents submitted this way are already communicated to the AT, so they don’t need to upload a monthly SAF-T file for them. The only documents that still require the monthly SAF-T upload are those not reported in real time, such as RG payment receipts, which the AT’s webservice does not accept.
Install the AT Portugal app, register the supplier with their NIF, and pick a reporting model (monthly SAF-T or real-time submission). Run invoices through the AT Issue Invoice workflow — Invopop generates the ATCUD, QR, and signature automatically.
When issuing in Portugal you may see an error similar to:
recording envelope: totals: (payable: too high according to Artigo 40.º do CIVA.)
What it means: Article 40 of the Portuguese VAT Code (Código do IVA) caps the amount a simplified invoice (fatura simplificada) can carry. The limits are:
  • €1,000 for goods sold by retailers or itinerant sellers to buyers who are not taxable persons (final consumers).
  • €100 for every other supply of goods or services.
  • No limit for suppliers under the Article 53 small-business exemption regime (since Decree-Law 35/2025).
Above the applicable limit, a simplified invoice is no longer allowed and the document must be a full invoice (fatura). Note that a simplified invoice can only carry the fields listed in Article 40, so adding the buyer’s name or address to it is not an option — the document type has to change.What to do:
  • Issue the document as a full invoice instead of a simplified one.
  • If the buyer is a taxable person (a business or a freelancer invoicing with a NIF), include their name, address, and NIF — Article 36 requires these identification elements only for taxable-person buyers.
  • If the buyer is a final consumer, no customer identification is required on a full invoice, whatever the amount. If you don’t have their details, set the customer name to Consumidor final and the tax ID to 999999990. Include their NIF only if they ask for it.
In GOBL, drop the simplified tag from $tags and adjust the customer block as above, then re-run the workflow.
What it means: when a credit note references an invoice issued through Invopop, every credit note line must be matched against the quantity and price still available to credit on the original invoice’s lines. Line #N could not be matched to any of them.For a credit note line to be applied to an invoice line:
  1. Its item.name must be exactly identical to the invoice line’s, and both lines must have the same VAT treatment — the same rate and, where applicable, the same exemption.
  2. Among the lines matching by name and VAT, it must satisfy one of:
    • Same unit price as the invoice line, with a quantity up to the remaining quantity — to credit fewer units at the original price.
    • Same quantity as the invoice line, with a unit price up to the remaining price — to credit part of the amount for the full quantity.
Include only the lines you are crediting — the credit note does not need to mirror the full invoice — and the order of the lines is irrelevant. Availability is cumulative: every accepted credit note reduces the remaining quantity or price, so the total credited per line can never exceed the original invoice amount.What to do: check that line #N’s item name and VAT rate or exemption exactly match a line on the referenced invoice (watch for typos or renamed items), and that it keeps either the original unit price or the original quantity as described above. If everything matches, review credit notes previously issued against the same invoice — the remaining quantity or amount may already have been credited.Note that a credit note supports exactly one preceding reference, and line matching only applies when the referenced invoice was issued through Invopop — references to external series (for example, invoices issued by a previous provider) are accepted without matching.
This error means your workflow includes the Send to the AT step for a payment receipt. Payment receipts are not supported for real-time reporting — the AT does not accept them via the real-time webservice.The fix: remove the Send to the AT step from your payment workflow. RG receipts are only reportable through the monthly SAF-T file. The Record for SAF-T reporting step alone is all you need for full compliance.
Portugal defines two payment receipt types:
  • RG — Outros Recibos: Standard payment receipts, reported through the monthly SAF-T file only. Real-time reporting is not available for this type.
  • RC — Recibo no âmbito do regime de IVA de Caixa: Receipts specific to the VAT Cash accounting regime. RC payments are not currently supported by the AT Portugal app.
See the Portugal tax regime in GOBL for tax categories, NIF rules, and AT-specific extensions. The pt-saft-v1 addon documents fields required by the SAF-T schema.

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Registering supplier questions

Run the AT Register Supplier workflow with the supplier’s NIF and chosen reporting model. Invopop registers the issuance series with AT and generates the ATCUD prefix to be embedded in every issued document.
For real-time submission, an AT API username/password is required (issued through the AT portal). For SAF-T monthly export, no live credentials are needed — only the supplier’s NIF and series registration.
For real-time submission, Invopop stores AT API credentials encrypted at rest. For SAF-T export model, no live credentials are needed — the supplier (or their accountant) downloads the SAF-T file and uploads it manually to AT’s portal.

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Reporting questions

Real-time model: per invoice. SAF-T model: once per month, by the 5th of the following month. The choice is set at supplier registration and can be changed by re-registering.
For invoice-level reporting, choose the model at supplier registration: real-time (Invopop submits per invoice) or monthly SAF-T (Invopop generates the file by the 5th of the following month, accountant uploads). Periodic VAT and IES are filed separately by the accountant.
Monthly SAF-T-PT XML uploaded to AT’s portal (no API for this), or real-time WebService XML calls per invoice. Both follow the same SAF-T schema; real-time submits one document at a time, SAF-T submits an aggregated file covering the month.

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