E-Invoicing in Portugal

E-invoicing process description

B2G e-invoicing is mandatory for large entities as of January 2021. In order to transfer and receive B2G e-invoices, suppliers and direct public administration entities are connected to the ESPAP’s portal FE-AP, the gateway of the state to financial documents. The documents are being transferred through a secure online connection (web service).

Generally, invoices must contain a QR code as of January 1, 2022 (though the QR code may be bypassed for taxpayers using electronic data interchange).

Under the current transitional regime, PDF invoices are considered valid "electronic invoices" for all tax purposes until December 31, 2026, even without a digital signature, provided they are issued by certified billing software.

B2G & B2B E-invoicing

In the B2G sector, the mandate is phased by company size. While large enterprises are already compliant, the deadline for SMEs and micro-companies was recently extended to January 1, 2027.

• Large Enterprises: More than 250 employees, annual sales over EUR 50 million, balance sheet total of EUR 43 million.
• Medium-Sized Companies: Fewer than 250 employees, annual sales no more than EUR 50 million, balance sheet total no more than EUR 43 million.
• Micro-Companies: fewer than 10 employees, annual sales or balance sheet total no more than EUR 2 million.

For B2B e-invoicing, there is no current plan for a mandatory structured format. The Tax Authority (AT) monitors the B2B sector via SAF-T billing reporting, the ATCUD/QR code system, and the upcoming SAF-T Accounting requirements.

How we can help

Comarch has signed several agreements with local providers to support B2B e-invoicing, which is not yet mandatory. Additionally, Comarch is connected to the governmental ESPAP platform for B2G transactions and can convert in-house formats to the required UBL 2.1/CIUS PT standard.