Briefing document & Podcast: E-Invoicing in Angola

Last update: December 16, 2025

SUMMARY

Summary:

Angola is implementing a phased rollout of electronic invoicing (e-invoicing) and electronic reporting (e-reporting) for VAT-registered businesses, starting in January 2026 and extending to all relevant taxpayers by late 2026. This mandate requires the use of certified software, adherence to a standardized data format (JSON), and real-time or near real-time transmission of invoice data to the General Tax Administration (AGT). The initiative aims to modernize Angola’s tax infrastructure, streamline compliance, and combat tax evasion. A “soft landing” transitional period with lenient enforcement has been in place, but penalties for non-compliance will be enforced.

Key Themes and Information:

1. Implementation Timeline and Phased Approach:

Presidential Decree No. 71/25 established the legal framework for e-invoicing, effective September 20, 2025.
Phase 1 (January 1, 2026): Mandatory e-invoicing for:
Large Taxpayers (“Grandes Contribuintes”)
Suppliers to the State (B2G transactions)
Transactions equal to or exceeding AOA 25 million (approximately €25,000).
Phase 2 (September 2026): Mandatory e-invoicing for all remaining VAT-registered taxpayers (General and Simplified VAT regimes). “Starting September 2026, all companies under the General or Simplified VAT regimes, regardless of size, must issue electronic invoices“
A “soft landing” period occurred between October 1, 2025 and December 31, 2025, allowing businesses to continue using traditional invoices without penalties. “During October–December 2025 , businesses could continue using traditional (paper) invoices with no penalties for non-compliance, while AGT finalized software certification and onboarding.”

2. Scope of Transactions:

All VAT-liable transactions in Angola require e-invoicing, including B2B, B2C, and B2G transactions.
This includes domestic and import/export transactions. “The law confirms that an invoice must be issued for every sale of goods, service provision, or advance payment carried out in Angola.”
Limited exemptions exist for certain transactions with end consumers (e.g., vending machine sales, public transport tickets), where simpler sales slips suffice.
Pro-forma invoices and other non-tax documents are explicitly not recognized as valid invoices.

3. Taxable Persons in Scope:

The mandate applies to all taxpayers with fiscal residence in Angola registered under the General or Simplified VAT regimes.
This includes both domestic and foreign companies operating in Angola and registered for VAT.
Very small businesses under the Exclusion/Exemption regime are technically out of scope but can opt-in voluntarily.

4. E-Invoicing Process and Requirements:

Certified E-Invoicing Software: Invoices must be generated through AGT-approved software (commercial or the free AGT e-invoicing web portal). Businesses can either use commercial software that has obtained AGT certification or adopt the free AGT e-invoicing web portal for manual invoice entry.
Standardized Invoice Format (JSON/XML): Electronic invoices must be issued in a structured digital format (JSON) as specified by Executive Decree No. 683/25.
Real-Time Transmission & Validation: Invoice data must be electronically sent to the AGT either immediately or within a very short timeframe. The AGT then assigns a unique identification code to each invoice. “while businesses do not have to wait for approval before delivering the invoice to the customer (since it’s “post-” issuance clearance), they do have to transmit the invoice data very promptly and obtain the tax validation code.”
Invoices lacking a valid AGT code are considered non-compliant.
Deadline for Issuing & Reporting: Invoice must be issued within 5 business days from the transaction.
Content Requirements: Mandatory invoice fields include seller/buyer details, invoice number, date of issue, description of goods/services, total price, VAT rate/amount, place/date of supply, and the AGT validation code.

5. E-Reporting:

E-reporting involves electronically transmitting invoicing data to the AGT.
This is accomplished through the AGT web portal or a machine-to-machine API.
Beyond invoices, taxpayers must report business locations, software systems, and invoice numbering series.
Annual SAF-T accounting files and year-end inventory listings are still required.

6. Relation to SAF-T:

Angola has a Standard Audit File for Tax (SAF-T) reporting system.
The e-invoicing mandate is separate from SAF-T but compatible.
Executive Decree 683/25 ensures the e-invoicing data structure is compatible with SAF-T requirements.

7. Grace Period and Transitional Arrangements:

A “soft-landing” period was implemented from October 1, 2025, through December 31, 2025, with no penalties for non-compliance.
A six-month adaptation period may be shown by authorities for initial non-compliance.
Voluntary early adoption of e-invoicing was possible.
The “Factura Premiada” (invoice lottery) program incentivizes consumers to demand electronic invoices.

8. Penalties for Non-Compliance:

Significant fines exist for various violations, including:
Failure to issue an invoice: 7% of the transaction value (15% for repeat offenses).
Incomplete or incorrect invoices: 5% of the invoice value (1% for minor omissions).
Late issuance: 0.2% of the invoice value.
Failure to transmit/report data: 7% of the invoice values involved (15% if repeated).
First-time offenders may receive a 50% reduction in fines.

9. Archiving Requirements:

Invoices and related fiscal documents must be retained for a minimum of 5 years.
Electronic invoices should be stored in their original digital format.

10. Pre-Filled VAT Returns:

The AGT will use e-invoicing data to pre-fill periodic VAT returns for taxpayers.
This aims to reduce manual errors and streamline compliance.

11. Regulatory and Source References:

Presidential Decree No. 71/25 of 20 March 2025 (“Regime Jurídico das Faturas”)
Executive Decree No. 683/25 of 22 August 2025 (technical specifications and data structure)
General Tax Code & VAT Code.

Conclusion:

Angola’s e-invoicing mandate represents a significant shift towards digital tax compliance. Businesses operating in Angola need to understand the phased implementation, technical requirements, and potential penalties to ensure compliance and avoid disruption to their operations. Staying informed and adapting systems is crucial.

INDEPTH ANALYSIS

Angola’s Electronic Invoicing (e-Invoicing) and Electronic Reporting (e-Reporting) framework is being rolled out in phases from 2025 into 2026, with mandatory compliance for all VAT-registered businesses by late 2026. Below is a comprehensive overview of the mandates, scope, timelines, requirements, and compliance details, based on the latest external sources and official regulations:

Implementation Timeline & Phases:
- March 20, 2025: Presidential Decree No. 71/25 published, establishing a new legal regime for invoicing (including e-invoicing). A 6-month vacatio legis (grace period) was provided, so the decree took effect on September 20, 2025. [onelegal.pt]
- Sept 2025 (Planned): E-invoicing was originally slated to become mandatory around late September 2025. However, technical difficulties delayed the rollout. [sovos.com]
- Oct 1, 2025 (Revised Start): The General Tax Administration (AGT) postponed the mandate to October 1, 2025. From this date, the system was available but with a transitional “soft landing” period through year-end. During October–December 2025, businesses could continue using traditional (paper) invoices with no penalties for non-compliance, while AGT finalized software certification and onboarding. [sovos.com]
- Jan 1, 2026 – Phase 1: Mandatory e-invoicing begins for in-scope taxpayers. From this date, electronic invoicing is compulsory for: (a) Large Taxpayers (designated “Grandes Contribuintes”), (b) suppliers to the State (B2G transactions), and (c) any transaction equal to or exceeding AOA 25 million (≈ €25,000). These groups must issue only electronic invoices via the certified system, and non-electronic invoices will no longer be accepted by the tax authority. (Taxpayers under these categories had their deadline postponed from Oct 2025 to Jan 2026 as noted above.) [kpmg.com] [comarch.com], [kpmg.com] [kpmg.com]
- Late 2026 – Phase 2: After a further grace interval, the mandate extends to all remaining VAT-registered taxpayers. Starting September 2026, all companies under the General or Simplified VAT regimes, regardless of size, must issue electronic invoices. In other words, by September 21, 2026 (12 months after the technical specifications were published in 2025), electronic invoicing becomes obligatory for all businesses in Angola’s VAT system. This final phase will cover small and medium enterprises that were not included in Phase 1. [kpmg.com], [edicomgroup.com] [edicomgroup.com]
- Note: The phased approach and deferred enforcement were designed to give businesses time to adapt. AGT officials have indicated that the first half of 2026 serves as an additional adjustment period – while e-invoicing is legally required from January 2026 for Phase 1 taxpayers, strict enforcement (penalties) may ramp up gradually over the ensuing months. [edicomgroup.com]
Scope of Transactions – Domestic vs. Cross-Border:
- All VAT-liable transactions in Angola require invoicing, and now must follow the new rules. The law confirms that an **invoice must be issued for every sale of goods, service provision, or advance payment carried out in Angola. This applies to business-to-business (B2B) and business-to-consumer (B2C) dealings alike, as well as business-to-government (B2G) transactions (especially in Phase 1 for state suppliers). The aim is to eliminate traditional paper invoices for virtually all taxable dealings once the system is fully implemented. [onelegal.pt] [edicomgroup.com]
- Domestic Transactions: All sales within Angola’s territory fall under the mandate. Even non-profit entities, public condominium management, and rental activities — which previously might not always issue invoices — are explicitly required to issue invoices under the new regime. Very limited exceptions are allowed (see “Exemptions” below). [beyond.co.ao], [beyond.co.ao]
- Import/Export Transactions: Invoices related to cross-border operations (export of goods/services, or import transactions) are also within scope of the e-invoicing requirements. The decree integrates these scenarios, with slight adaptations (for example, invoices for exports/imports can state amounts in a foreign currency rather than in Angolan Kwanza). Thus, even international trade involving Angolan VAT-registered businesses must be documented by an invoice that meets the new electronic format (or reported via the authorized portal). [beyond.co.ao]
- Exemptions & Special Cases: Certain transactions with end consumers (natural persons) have invoicing exemptions or simplified documentation: e.g. sales via vending machines, public transport tickets, street/market vendor sales, etc., do not require a full invoice when the buyer is an individual. In such cases a simpler sales slip or ticket suffices. Besides these, all other transactions require proper invoices. (These exemptions mirror prior practice and remain in place, but they represent a narrow slice of transactions.) Additionally, invoices issued by existing certified tax cash registers or equivalent electronic systems (if already compliant) and certain specific document types may be treated as compliant – but generally, pro‐forma invoices and other non-tax documents are explicitly not recognized as valid invoices. In summary, the mandate captures the vast majority of commercial transactions in Angola, including domestic and cross-border, with only minor exceptions for certain retail scenarios. [onelegal.pt]
Taxable Persons in Scope (Established vs. Non-Established):
- Established Businesses: The e-invoicing obligation applies to all taxpayers with fiscal residence in Angola who engage in economic activities and are registered under either the General VAT regime or the Simplified VAT regime. This includes corporations, professionals, and even non-profit organizations when they conduct taxable transactions. In practice, all VAT-registered businesses in Angola will be required to comply by Phase 2. Initially, “Large Taxpayers” (as defined by Angola’s tax administration, generally those handled by the Large Taxpayers Unit) were targeted first, as well as companies that supply goods/services to the government. Over time, the net widens to include medium and small enterprises as well. [angolex.com] [edicomgroup.com] [onelegal.pt] [vatabout.com]
- Non-Established Entities: If a foreign or non-resident company is engaged in taxable activities in Angola and is required to register for Angolan VAT (thus obtaining a taxpayer identification number and “fiscal residence” in Angola for tax purposes), it falls under the same e-invoicing requirements. The law’s scope is defined to cover taxpayers with fiscal residence in Angola including both domestic and foreign companies operating in the country. Therefore, a non-established entity that is VAT-registered (e.g. through a local branch or tax representative) must issue electronic invoices for its Angolan transactions, just like a locally incorporated business. [edicomgroup.com], [edicomgroup.com]
- VAT Regimes: Angola’s VAT system has tiers – General Regime (larger businesses) and Simplified Regime (small businesses with moderate turnover, between AOA 25 M and 350 M annually), as well as an Exclusion/Exemption Regime (micro businesses below the VAT threshold). All General and Simplified regime taxpayers come under the e-invoice mandate by 2026. Those under the Exemption regime (very small taxpayers not charging VAT) are technically out of scope for mandatory e-invoicing; they may continue using pre-printed paper invoices authorized by AGT. However, even exempt-regime taxpayers can opt into electronic invoicing voluntarily with AGT’s approval. (In fact, the law allows any taxpayer to voluntarily adhere earlier, subject to authorization.) [edicomgroup.com] [onelegal.pt] [beyond.co.ao]
- Phase 1 Criteria: The initial wave (Jan 2026) targets “Grandes Contribuintes” which generally refers to the largest enterprises under the Large Taxpayer Office. Although Presidential Decree 71/25 does not explicitly list a revenue threshold for this category in the text available, guidance suggests it includes companies with significant turnover (anecdotally, turnover above AOA 25 million was mentioned as a criterion for phase 1 in one summary, though that threshold appears quite low; practically, the tax authority’s existing designation of “large taxpayer” likely applies). Additionally, “state suppliers” of any size must comply from the start. Crucially, any single invoice of very high value (≥ AOA 25 million) triggers an e-invoice requirement as well – meaning even a smaller company not yet generally mandated to e-invoice would have to issue that particular invoice electronically or via the tax portal. This rule ensures that all major high-value transactions are captured electronically, even during the transitional period. [vatabout.com] [edicomgroup.com] [edicomgroup.com], [beyond.co.ao]
- Phase 2 (All Taxpayers): After the first year of large-taxpayer rollout, the obligation extends to all VAT taxpayers. By late 2026, any business registered for VAT in Angola (whether domestic or foreign, large or small) must issue invoices electronically for their taxable operations. In short, established and non-established VAT registrants alike are in scope, with only the timing of inclusion differing by size/type until full implementation. [kpmg.com]
E-Invoicing Process and Requirements:
- Certified E-Invoicing Software: All invoices must be generated through a certified or validated software system approved by the AGT. The Ministry of Finance and AGT have defined technical criteria for these systems in Executive Decree No. 683/25 (22 August 2025). Businesses can either use commercial software that has obtained AGT certification or adopt the free AGT e-invoicing web portal for manual invoice entry (the portal is mainly intended for very small invoice volumes). The chosen solution must support the mandated data format and security features (digital signing, audit trail, etc.). During Q4 2025, AGT focused on validating various software solutions to ensure readiness for the mandate. [kpmg.com] [kpmg.com] [vatabout.com], [onelegal.pt] [comarch.com]
- Standardized Invoice Format (JSON/XML): Electronic invoices in Angola must be issued in a structured digital format that can be automatically processed. According to the technical specifications, the required format is a structured data file (JSON) submitted via the system. (Some sources generically refer to “XML format”, but the official decree specifies a JSON schema for the data payload.) Each invoice’s data—buyer and seller details, line items, totals, taxes, etc.—is formatted per this standard and then transmitted to the tax authority’s platform. [vatabout.com], [vatabout.com] [openenvoy.com]
- Real-Time Transmission & Validation: Angola’s model is described as “post-clearance” but with real-time reporting. In practice, this means when an invoice is issued, its data must be electronically sent to the AGT either immediately or within a very short timeframe. The AGT e-invoicing platform (accessible via a web portal or through a REST API for integrated software) receives the invoice data and performs basic validation checks. The tax authority then assigns a unique identification code (validation code/hash) to each invoice that passes validation. This code is returned to the issuer and must be included on the final invoice document. The process is effectively a clearance system: while businesses do not have to wait for approval before delivering the invoice to the customer (since it’s “post-” issuance clearance), they do have to transmit the invoice data very promptly and obtain the tax validation code. Invoices that lack a valid AGT code are considered non-compliant and, for example, ** purchasers cannot use them to support VAT input tax credits. This incentivizes both sellers and buyers to ensure invoices go through the official system. [vatabout.com] [vatabout.com], [openenvoy.com] [vatabout.com], [beyond.co.ao]
- Deadline for Issuing & Reporting: The legal deadline to issue an invoice is within 5 business days from the underlying taxable transaction (the sale or service completion). For continuous or ongoing services, an invoice can cover up to one month of transactions (and must be issued by the end of that month). These timelines essentially serve as the outer limit for reporting to AGT as well – since issuing the invoice and transmitting it are part of one integrated process in e-invoicing, invoice data should be uploaded to the system no later than 5 business days after the transaction. In practice, when using certified software with API integration, this happens instantaneously at the time of invoice generation. The “within 5 days” rule provides a bit of leeway for certain cases (e.g. if a system issue delays transmission, or for manual portal entries), but real-time or same-day submission is the norm. [onelegal.pt]
- Content Requirements: All mandatory invoice fields under Angolan law must be present in the e-invoice. The decree and subsequent regulations specify that an invoice (in Portuguese) must include at least: seller’s and buyer’s name, address, and Tax ID (NIF); a unique sequential invoice number and the year; date of issue; description of goods/services supplied (with quantities and unit prices); the total price in local currency (AOA) in figures (and in words for the total); the applicable VAT rate(s) and amount of tax, or a reference to the legal provision for any exemption or zero-rating; the place and date of the supply (i.e. where and when the goods were delivered or service rendered, which may differ from the invoice issue date); and an identification of the certified software or authorized printing center that produced the invoice. Electronic invoices have additional elements such as the time of supply (hour/minute) and the digital hash/validation code from AGT on the document. Also, when printed, the first copy of an invoice should be marked “Original” to distinguish it from duplicates. These content rules apply equally to credit notes and debit notes, which are used for invoice adjustments; a credit note must state the reason for the correction or cancellation of an invoice. Receipts (proof of payment) are also mandated when an invoice is paid fully or partially, unless the invoice itself was issued as an “invoice-receipt” combined document. (The e-invoicing system captures receipts as well, and they carry similar data requirements except they don’t list the sold items again.) [beyond.co.ao] [onelegal.pt], [onelegal.pt] [onelegal.pt] [beyond.co.ao], [vatabout.com]
- Exclusions of Certain Documents: The law explicitly lists documents that cannot substitute for an invoice – for example, pro-forma invoices, purchase orders, delivery notes, quotations, etc., are not valid fiscal invoices. This is to prevent any ambiguity: only a duly issued invoice (or an authorized equivalent like an invoice-receipt) counts for tax purposes. Any attempts to use other documents in lieu of a proper invoice would violate the rules and are subject to penalty. [onelegal.pt]
- Unique Invoice Series & Controls: Each taxpayer must maintain proper sequencing of invoices (often organized into series). Under the new system, companies have to declare the identification of each invoice series (number range) they use, both used and unused, to the tax authority. In practice, the certified software will handle sequential numbering and prevent duplicates, but this reporting ensures AGT knows all potential invoice sequences assigned to a business. [onelegal.pt]
- Software Security and Audit Trail: Certified invoicing systems are required to ensure authenticity and integrity of the invoices from issuance through the archival period. In Angola’s model, this is accomplished by means such as the hash code (digital signature) on each invoice and robust software audit logs. The system must keep an immutable record of all issued documents. The AGT reserves rights to inspect the systems – including on-site audits or even remote access to the software – to verify compliance with technical requirements. Software providers and users must also supply any technical documentation needed for audits. [beyond.co.ao]
- Contingency Procedures: If a taxpayer’s e-invoicing system goes down or loses connectivity, the rules allow for contingency invoice issuance. In such cases, a business can temporarily issue invoices offline – either using an “offline mode” of the software or even reverting to pre-printed paper invoice booklets (obtained from an authorized printer) as a last resort. Each invoice issued in contingency must be clearly marked with a phrase like “Issued in contingency, pending authorization”. The taxpayer is required to notify AGT immediately about the system outage, and once the system is restored, all contingency-issued invoices must be submitted to the AGT platform for validation without delay. There is also a limit: using paper invoices in this manner is allowed for a maximum of 45 days in a row (after which the taxpayer is expected to have resolved the issues). These measures ensure that even technical difficulties do not exempt a business from ultimately reporting its invoices electronically. [beyond.co.ao]
- Low-Volume Taxpayers: Entities that issue very few invoices (the law mentions ≤ 300 invoices/year as a threshold) have the option to use the AGT’s free “Portal do Contribuinte” (Taxpayer Portal) to issue invoices instead of maintaining their own certified software. This is especially aimed at individuals or exemption-regime businesses. The portal is effectively an online invoicing tool provided by the government; invoices issued through it are, by design, in compliance (they’ll receive the AGT validation codes). However, this method may be impractical for larger businesses due to manual entry and possible performance bottlenecks during peak times. Most medium/large taxpayers will use their own integrated software. [onelegal.pt], [beyond.co.ao] [vatabout.com]
- Relation to SAF-T: Notably, Angola had introduced a form of Standard Audit File for Tax (SAF-T) reporting in 2019 (often referred to as “SAF-T (AO)”). That system required businesses to periodically submit structured data files of their accounting records, including invoices, to the tax authority for audit purposes. The new e-invoicing mandate is separate from SAF-T in that it involves transactional, near-real-time reporting (rather than after-the-fact audit files). However, the two systems are complementary: the Executive Decree 683/25 ensures that the e-invoicing data structure is compatible with SAF-T requirements. In practice, businesses must continue to generate annual SAF-T accounting files (with full prior-year data) and annual inventory files for submission by set deadlines, but the hope is that with e-invoicing, a lot of data is already with the tax authority in real time, which can streamline audits and even allow pre-filled returns (as discussed later). [vatabout.com] [kpmg.com] [edicomgroup.com]
E-Reporting (Data Transmission to Tax Authorities):
In Angola’s context, “e-reporting” refers to the obligation to electronically transmit invoicing data and related tax information to the General Tax Administration (AGT). This is inherently part of the e-invoicing system, rather than a separate process, except for certain periodic reports like SAF-T.
- Real-Time Invoice Reporting: As described, every invoice issued by a taxpayer under the mandate must be electronically reported to the AGT platform at the time of issuance (or within days at most). The mechanism for this is either the AGT web portal (where the data is entered online) or via a machine-to-machine API from certified billing software. Transmission is immediate in the case of API integration – the software will automatically send the invoice data in the required format to an AGT server and receive a response (validation code or error message). If the transmission fails or the invoice is rejected due to errors, the business must correct and resend the data. This process constitutes electronic reporting of each invoice to the tax authority. [openenvoy.com] [vatabout.com]
- Acknowledgment by AGT: Upon successful transmission, AGT’s system validates the data and returns the unique validation code. This code in effect is an acknowledgment that the invoice has been registered with the tax authority. It also serves as a control number that officials (or even customers) can use to verify an invoice’s authenticity. The presence of this code (or digital signature) on an invoice indicates it was properly reported; absence of a code means it wasn’t reported/accepted.
- Timeline for Data Submission: For each invoice, the data must be sent no later than 5 business days after the taxable event (which coincides with the legal issuance deadline). However, since the intent is to have real-time oversight, companies are generally expected to transmit on the same day as invoice issuance, especially when using automated systems. The law essentially requires continuous reporting of invoices throughout the tax period, rather than a monthly or quarterly batch report. This is often described as a move from periodic returns to transaction-level reporting. [onelegal.pt]
- Electronic Transmission of Other Data: Beyond individual invoices, taxpayers are obliged to report certain information electronically to the tax authorities: for instance, notification of their business locations, the software systems in use at each location, and the numbering series for their invoices must be sent to AGT (this is a one-time or on-change report). Moreover, yearly electronic files are still required for full accounting data (SAF-T AO for the financial year by April 10) and year-end inventory listings (by Feb 15). These fall under e-reporting obligations aimed at giving the tax authority a complete picture of the taxpayer’s financials. [onelegal.pt], [beyond.co.ao] [edicomgroup.com]
- E-Reporting for Exempt/Small Taxpayers: Those not yet mandated to do real-time e-invoicing (e.g., during the transition or small exempt businesses) must still comply with reporting their invoices through other means. The law stipulates that even exemption-regime taxpayers or individuals using paper invoices should communicate their invoice information to AGT via the SAF-T file. In practical terms, this likely means that such taxpayers will include all their issued invoices in the periodic SAF-T submission, or use the portal to issue them so that they are captured. By Phase 2 (after Sept 2026), this becomes moot since everyone issuing VAT invoices will be doing so electronically anyway. [onelegal.pt]
- Transmission Channels & Format: The authorized channel is either direct use of AGT’s E-invoicing Portal or a web service (API). The data format (JSON as per Exec. Decree 683/25 technical specs) ensures that what is transmitted is standardized and can feed into the tax authority’s databases. The SAF-T file for Angola is an XML-based format aligning with OECD standards, and the decree indicates that the e-invoice data structure is aligned so that the invoices can be part of the SAF-T data. Thus, Angola’s e-reporting can be seen as a hybrid of real-time transmission for each invoice and periodic submission of comprehensive data files for audits. [vatabout.com] [kpmg.com]
- Reporting Timelines Summary:
  - Invoices: within 5 business days of each transaction (ideally instantly at issuance). [onelegal.pt]
  - Credit/Debit Notes: same as invoices – must be reported when issued (these adjust or cancel invoice records).
  - Receipts: reported when issued (these tie to invoices and get transmitted similarly).
  - High-Value Transactions: any invoice ≥ AOA 25 M must be reported via portal or software at the time of that transaction, even if the issuer is not otherwise in scope yet. [edicomgroup.com]
  - Annual Inventory file: by Feb 15 each year (for previous year’s ending inventory). [edicomgroup.com]
  - Annual Accounting SAF-T: by Apr 10 each year (for previous fiscal year’s accounts). [edicomgroup.com]
  - Business/Software info: upon implementation and whenever changes occur (locations, software, series info must be kept updated with AGT).
    These requirements ensure continuous compliance and data availability for the tax authority, effectively replacing certain monthly/quarterly reports with either real-time data or annual comprehensive files. [onelegal.pt]
- Data Reception and Use: Once transmitted, invoice data is stored in AGT’s system. This data enables the tax authority to perform cross-checks (e.g., matching sales and purchases between companies), track VAT liabilities, and even pre-fill tax returns (as discussed below). It also means businesses must ensure accuracy in what they report, since any mistakes in the electronic data are immediately visible to the authority and could trigger audits or require corrections. The system performs some validation on data (format checks, arithmetic checks, valid TINs, etc.), and non-compliant invoices (with errors or missing info) are rejected at submission, prompting the issuer to fix them. This real-time feedback loop is a core advantage of the e-invoicing regime. [vatabout.com]
- E-Reporting vs. Traditional VAT Return: With transaction-level e-reporting in place, the traditional model of filing a detailed monthly/quarterly VAT return listing sales and purchases is transformed. Angola is moving towards using the e-invoice data to automatically calculate what each taxpayer’s VAT due should be. As a result, the periodic VAT return (Declaracão Periódica de IVA) can be pre-populated by the tax authority with the totals from e-invoices and e-reporting data. Taxpayers then just confirm or adjust the pre-filled return. This integration greatly depends on the quality and completeness of e-reporting. [ey.com]
Grace Period and Transitional Arrangements:
- Soft-Landing Period (Q4 2025): As noted, from Oct 1, 2025 through Dec 31, 2025, Angola implemented a grace period for the e-invoicing rollout. During this phase, no penalties were applied if a taxpayer did not issue electronic invoices. Companies were effectively allowed to continue their normal invoicing process (paper or other formats) while they prepared for the new system. The AGT used this period to continue certifying software solutions and assisting businesses in the transition. This was officially communicated by AGT in late September 2025 when announcing the postponement of the original go-live. The grace period is sometimes termed a “transitional period” in which e-invoicing was encouraged but not enforced. [sovos.com] [comarch.com], [sovos.com] [kpmg.com]
- January 2026 Onward: From January 1, 2026, the grace period for Phase 1 ends – meaning large taxpayers, state suppliers, and any invoices ≥ 25M Kz must fully comply with e-invoicing, or face penalties. Traditional paper invoices cease to be accepted for these in-scope taxpayers/transactions. Essentially, this is the hard cutover date where electronic invoicing becomes obligatory (after the three-month soft launch). AGT officials confirmed that from this point, failing to issue an e-invoice where required is a violation. [comarch.com]
- Phase 2 Ramp-Up: For the rest of taxpayers (medium/small businesses under general or simplified VAT regimes), the “grace period” is effectively extended until their mandate begins in 2026. Throughout the first 9 months of 2026, those not in Phase 1 can watch and learn as the large companies pave the way. By September 2026, however, everyone is in. It’s expected that a similar “no penalty” buffer might be considered in late 2026 for the newest adopters, but the decree explicitly mentions a 12-month phased introduction and then full coverage, implying that by late 2026 enforcement is uniform. [beyond.co.ao]
- Six-Month Compliance Window: The legislation built in a notion of a six-month adaptation period after entry into force. For example, Decree 71/25 took effect in Sept 2025, but mandatory enforcement was not until Mar 2026 for large taxpayers (roughly 6 months later) – which aligns with the January 2026 date plus a “soft” enforcement until March. Sources indicate that authorities may show leniency for initial non-compliance for up to 6 months after a mandate kicks in, to allow companies to adjust without immediately facing harsh penalties. However, this should not be confused with an official extension; it’s more about practical enforcement discretion. Businesses are strongly expected to be compliant by the deadlines (Jan 2026, Sept 2026 as applicable) to avoid risks. [edicomgroup.com]
- Voluntary Early Adoption: Prior to the mandatory dates, voluntary adherence was possible. Some companies, particularly those already using invoicing software, opted to start e-invoicing in 2025. The law allowed any taxpayer, even those under the VAT Exclusion regime, to opt in early by requesting authorization from AGT. This gave them a head start and perhaps smoother transition. It also allowed AGT to pilot the system with willing participants. [beyond.co.ao]
- Invoice Lottery (“Factura Premiada”): Alongside the technical grace period, the government introduced an incentive mechanism to encourage compliance from day one. The “Factura Premiada” is a lottery program where consumers can win prizes based on the invoices they collect. Every valid invoice issued to a final consumer can serve as a lottery ticket in draws organized by the tax authorities. This program started in late 2025 to motivate consumers to demand electronic invoices (thus pressuring businesses to issue them). While not a “grace period” per se, this measure is a transitional compliance boost strategy. It signals that after the grace period, customers may play a role in policing compliance by insisting on proper invoices so they can participate in the lottery. [onelegal.pt]
Penalties for Non-Compliance:
Angola’s new invoicing regime comes with a strengthened sanction framework for violations. Non-compliance can result in significant fines, generally calculated as a percentage of the invoice value in question. Key penalties outlined in Presidential Decree 71/25 (Article 35) include: [onelegal.pt]
- Failure to Issue an Invoice: If a sale of goods or services that should have been invoiced is made without generating any invoice, the penalty is 7% of the value of that transaction. This fine increases to 15% of the transaction value if the offense is repeated (i.e. for a second infraction of the same nature). This targets under-the-table sales; a 7–15% penalty can wipe out the profit margin and serves as a strong deterrent. [onelegal.pt]
- Incomplete or Incorrect Invoices: If an invoice is issued but missing mandatory details (for example, missing a taxpayer ID, or not listing the tax due, etc.), the law provides for a penalty of 5% of the invoice’s value. However, for certain minor omissions the fine can be 1% – the decree differentiates the severity based on which detail is missing (perhaps higher penalty for missing key fields like tax ID or amount, and lower for less critical fields). In any case, not adhering to the content requirements (see above) carries financial risk. [onelegal.pt]
- Late Issuance (Timing Violation): If an invoice is issued past the deadline set by law (beyond 5 business days after the transaction, or after the allowed monthly period for continuous supplies), the penalty is 0.2% of the invoice value. This is smaller in percentage, reflecting that the invoice exists and presumably tax is accounted, but it was not timely. Still, for large invoices, even 0.2% could be a non-trivial amount. This underscores the importance of prompt invoicing/reporting. [onelegal.pt]
- Failure to Issue a Receipt: If a required receipt for payment (when an invoice is paid) is not issued, the fine is 1% of the related invoice’s value. This ensures that the audit trail of payments is maintained (receipts link payments to invoices, preventing businesses from hiding cash receipts off-books). [onelegal.pt]
- Failure to Safeguard/Archive Invoices: If a taxpayer does not keep invoices and related fiscal documents in proper custody for the required retention period, a penalty of 1% of each invoice’s value can be imposed. This rule emphasizes the need for proper archiving (physical or digital) as mandated by law. Losing records or failing to store them as required is an offense. [onelegal.pt]
- Failure to Transmit/Report Data (SAF-T or e-Invoice): If a taxpayer fails to submit the required electronic data files – for example, not sending the annual SAF-T file, or if the file is submitted with significant errors/omissions – the penalty is the same as if they failed to issue the invoice at all. In the decree, it equates this to the first category (sale without invoice), i.e. 7% of the invoice values involved (15% if repeated). Essentially, not reporting your invoices to the tax authority is treated on par with not issuing them. This covers scenarios like not uploading invoices through the system, or not providing the SAF-T data extract if required. It highlights that the reporting aspect is just as crucial as the issuance. [onelegal.pt]
- General Non-Compliance: The decree’s sanction chapter allows AGT to consider any breach of the new invoice regime as a tax offense (contra-ordenação). There may be other fines (for instance, use of non-certified software could itself be penalized, though primarily the result would be treated as non-issued invoices). Also, if fraud is detected (e.g. deliberate manipulation or use of fake invoices), there could be heavier legal consequences beyond administrative fines (potentially criminal charges in severe cases). [angolex.com]
- Penalty Mitigation: For a first-time offense, the law provides that the above fines are reduced by 50%. This means if a company slips up initially (perhaps issues a few invoices incorrectly), the penalty can be half of the listed rate, as an encouragement to correct behavior. However, this reduction does not apply to repeat offenses. It’s essentially a leniency for good-faith first errors. [onelegal.pt]
- Enforcement: After the grace period, AGT has indicated it will enforce these penalties. For the period Oct–Dec 2025, they explicitly did not enforce penalties for non-use of e-invoicing, but starting 2026, companies not complying can expect to be fined. Moreover, since an invoice without an AGT code is invalid for VAT deduction, even aside from government fines, businesses have a market incentive: their buyers (especially business customers) will demand proper electronic invoices so they can claim their input VAT. This mutual pressure helps enforce compliance. [sovos.com]
- Key Compliance Tip: Companies are advised to train their staff on these new rules and monitor their invoicing closely during the transition. Common issues like invoice rejections by the system need to be resolved quickly to avoid situations that could lead to penalties (e.g., an invoice initially rejected but not corrected could be seen as “not issued” in the system). Keeping software updated and maintaining an audit trail will help demonstrate compliance if audited. [vatabout.com]
Archiving Requirements & Retention Period:
- Retention Period: Under Angola’s General Tax Code and the new invoicing decree, invoices and related fiscal documents must be retained for a minimum of 5 years for VAT purposes. (This five-year period typically starts from the end of the fiscal year in which the invoice was issued, aligning with general record-keeping and audit timeframes.) In practice, many businesses keep records for longer (e.g. 7 years or more) in case of extended audits, but 5 years is the legal minimum for VAT invoice retention in Angola. [openenvoy.com]
- Archiving Format: Electronic invoices should be stored in their original digital format with all authenticity and integrity features intact. The law (Pres. Decree 71/25) dedicates a chapter to archiving of invoices (Cap. IV) and requires that invoices be preserved either physically or electronically in a way that guarantees their legibility, authenticity, and integrity throughout the retention period. For e-invoices, this means the digital files (JSON/XML and any human-readable renderings) along with their digital signatures/hashes must be kept and protected from alteration. If invoices are initially issued in paper (e.g., contingency invoices), the paper originals must be archived. [beyond.co.ao]
- Storage Method and Approval: Taxpayers can archive electronically, but they must ensure the system meets the conditions of the law. AGT can audit the archiving method – including conducting on-site checks at companies or at third-party providers that store invoices – to verify that all legal requirements are met. Companies should have documentation on their archiving process (backup schedules, security measures, etc.) available for inspection. [beyond.co.ao]
- Location of Records: The General Tax Code usually requires that records be kept within Angola or be readily accessible to the tax authority. If using cloud storage or an overseas service, businesses might need to get authorization or ensure access for AGT. (The decree allows AGT direct electronic access to invoicing systems for compliance checks, implying that on-demand access to archives could be requested.) [beyond.co.ao]
- Consequences of Poor Archiving: As noted, failing to keep invoices can lead to fines (1% of invoice value per missing document). Beyond fines, inability to produce an invoice during a tax inspection could result in that sale being disqualified (e.g., output VAT still due, but buyer’s input VAT denied, etc.). Therefore, proper archiving is an essential part of compliance. [onelegal.pt]
- Period Extension: If any litigation or audit involving certain invoices is ongoing, generally those invoices must be kept until that is resolved, even if it exceeds 5 years. The 5-year rule is the baseline for normal circumstances. Also, other laws (like commercial law) might prescribe longer retention (often 10 years for accounting records), so many companies align to the longest relevant period for safety.
- Electronic vs Paper Archives: Before e-invoicing, many businesses stored paper copies of all invoices (often required since invoices were physical or printed). With e-invoicing, the digital file with its security features is the primary record. Companies may still choose to keep printed copies for internal use, but legally the digital version suffices if it can be reproduced on demand. The decree ensures that the digital format is legally recognized as equivalent to paper for audit purposes, as long as integrity is assured. [beyond.co.ao]
- Audit File (SAF-T) Storage: The yearly SAF-T (AO) accounting and inventory files that are submitted to AGT are essentially snapshots of the records. It’s prudent for businesses to archive those submitted files as well, since they represent what was reported. Those should also be kept 5+ years.
- Summary: In summary, invoices, whether electronic or paper, must be safely archived for at least five years. During this time, they must remain accessible and unaltered. The e-invoicing system’s design (with digital signatures and unique codes) helps enforce integrity, but the company is responsible for maintaining those records. The tax authority’s enhanced IT systems may also retain a copy of each invoice (since they are transmitted to the government), but that does not absolve the taxpayer from their own storage duty. [openenvoy.com]
Pre-Filled VAT Returns (Declaracão Periódica do IVA):
- A significant benefit of Angola’s e-invoicing and e-reporting reform is the move toward pre-populated VAT returns. The AGT has indicated that it will use the detailed data collected from electronic invoices to pre-fill the periodic VAT declaration (DP IVA) for taxpayers. Essentially, because every sales invoice is reported and (eventually) every purchase invoice can be matched, the tax authority can compute a taxpayer’s tentative VAT payable or refundable. [ey.com]
- Mechanism: When it’s time to file the VAT return (which in Angola is typically a monthly or quarterly filing, depending on the regime), the taxpayer will find that the form on the tax portal already contains entries – for example, the total output VAT from all the sales invoices they issued in that period, and possibly the total input VAT from purchase invoices that their suppliers have issued (if those are cross-referenced to the taxpayer’s TIN). This pre-filling is made possible by the real-time invoice submissions. It aims to reduce manual errors and streamline compliance. Taxpayers will need to review the pre-filled values, reconcile them with their own records (to ensure nothing is missing or incorrect), and then confirm the return. If there are transactions that were not captured (e.g. perhaps some special cases or corrections), the taxpayer can adjust the return before submission.
- Current Status: As of late 2025, pre-filled VAT returns are being introduced alongside the e-invoice rollout. EY Angola notes this development, suggesting that taxpayers and their accounting systems need to be prepared to align with the government-provided figures. This indicates that AGT likely launched the pre-filled return system for the 2026 tax periods, once they start getting data from January 2026 invoices. [ey.com]
- Implications: Pre-filled returns, if accurate, make compliance easier – potentially just a review-and-submit process. However, any discrepancy between a business’s internal records and the tax authority’s data would need to be resolved. For example, if a company failed to transmit a few invoices, those sales would not appear in the pre-filled return (since AGT didn’t record them) – but legally, the company must still report them and pay the VAT. This would alert the company that those invoices might not have been properly e-reported, prompting corrective action. Conversely, if the company’s input VAT is lower than expected, perhaps a supplier didn’t e-report an invoice; the purchaser would then follow up with that supplier. In this way, pre-filled returns create an incentive for all parties to comply with e-invoicing, as missing data immediately affects return totals.
- No Pre-Filling if Not Applicable: It’s worth noting that pre-filled returns likely apply to the periodic VAT return form. Other tax filings (like corporate income tax) are outside this system. Also, very small taxpayers under the simplified regime might not have fully pre-filled returns if they were not e-invoicing yet (until Phase 2). But from the point the system is universal, we can expect broad usage of pre-populated VAT declarations.
- Reconciliation Services: The introduction of this feature has led firms (including consulting companies) to offer services to help taxpayers reconcile their accounting data with the AGT’s pre-filled VAT return. This underscores that while the process should reduce manual data entry, companies must still ensure their reported data is complete and correct, or else their tax filings will be off. In any case, Angola’s embrace of pre-filled VAT returns puts it on the cutting edge of tax administration in the region, leveraging digital reporting to simplify compliance. [ey.com]
Regulatory and Source References:
- Presidential Decree No. 71/25 of 20 March 2025 – “Regime Jurídico das Faturas” – is the cornerstone of Angola’s new invoicing rules. It consolidates requirements for issuing, rectifying, and archiving invoices, and it legally establishes the obligation of electronic invoicing (with phased implementation). It also introduced the consumer lottery incentive and updated the penalties for non-compliance. This decree was published in the official gazette (Diário da República) and took effect in Sept 2025. [onelegal.pt] [beyond.co.ao] [beyond.co.ao], [onelegal.pt]
- Executive Decree No. 683/25 of 22 August 2025 – issued by the Ministry of Finance – provides the technical specifications and data structure for e-invoicing, as well as procedural details for the electronic system. It covers the format (schema) of the invoice data (which sources indicate is JSON/SAF-T aligned), the requirements for software certification, and the operational guidelines for real-time transmission. This was an essential piece that allowed software providers to adapt and integrate with the AGT system. (The Executive Decree was published after a draft was circulated; it’s sometimes referenced in summaries as containing the “how” of e-invoicing). [kpmg.com] [vatabout.com]
- General Tax Code & VAT Code: Pre-existing tax laws in Angola (like the Código Geral Tributário and the VAT Code) already had provisions on invoice obligations and record-keeping. Decree 71/25 updates and overrides those where conflicting, but many principles (like 5-year record retention, requirement to issue invoices for all sales, etc.) were consistent with prior law. The VAT Code (Law 7/19 and amendments) defines who must register for VAT and basic invoicing obligations, which are now elaborated by the new decree.
- Administrative Instructions: AGT has released circulars and guidance (some referenced in the decree, which “consolidated information that was in Circulars and directives of AGT over recent years”). For example, AGT’s announcement on 23 September 2025 formally postponed the go-live to Oct 1, 2025, and this was communicated via a press release. Additionally, AGT and the Ministry have used public channels (news media and their websites) to announce the key dates (such as confirming the Jan 2026 start for large taxpayers). [beyond.co.ao] [kpmg.com]
- Government Portals: The Angolan government and tax administration websites (for instance, the Ministry of Finance or AGT portal) have published news articles on the e-invoicing rollout. For example, a government news portal noted “AGT: Aplicação de factura electrónica começa em Janeiro de 2026” (AGT announced e-invoicing will begin in Jan 2026), aligning with the Phase 1 mandate. These communications often reiterate the phased approach and encourage taxpayers to get ready. While much official info is in Portuguese, summaries by global tax firms have translated and clarified these points in English.
- External Tax Advisories: Numerous accounting and tax advisory firms have issued alerts and newsletters in 2025 detailing Angola’s e-invoicing requirements. For instance:
  - KPMG published TaxNewsFlash updates in Oct 2025 about the mandatory e-invoice legislation, its postponement, and new timelines. [kpmg.com], [kpmg.com]
  - EY Angola released a Portuguese alert highlighting the Jan 2026 mandate and the need to adapt systems, also mentioning the pre-filled VAT returns initiative. [ey.com], [ey.com]
  - Deloitte/VATupdate and others provided briefings (including podcasts) on the 2025 transition and 2026 full mandate.
  - Sovos (a tax compliance firm) and Comarch (an e-invoicing solution provider) posted updates confirming the grace period and new deadlines. [sovos.com], [comarch.com]
  - VATabout (Dec 2025) offered a detailed write-up of Angola’s phased implementation and system details. [vatabout.com], [vatabout.com]
  - EDICOM (Oct 2025) and local consultancies (OneLegal, Beyond, etc.) explained the legal provisions and practical steps. [edicomgroup.com], [beyond.co.ao]
- Regulatory Links: For primary sources, one can refer to the official text of Presidential Decree 71/25 (available on Angolan legal portals) and any published Ministerial Decrees/Dispatches from AGT for technical standards (Exec. Decree 683/25). The Angolan General Tax Administration’s website or the Ministry of Finance’s site may host these or provide summaries. Given language considerations, many rely on the summarized translations by professional services firms (which we have cited above). [angolex.com]
- In conclusion, Angola’s e-invoicing and e-reporting framework is well-documented through a combination of official legal texts and recent analyses by tax professionals, all of which consistently outline the mandate’s scope, timeline, and requirements as summarized here. This coordinated effort marks a significant modernization of Angola’s tax infrastructure, bringing it in line with global trends in digital tax compliance. [openenvoy.com]

Sources: The information above is drawn from Angola’s official decrees and announcements, and is cross-verified by recent updates from reputable external sources including KPMG, EY, VATupdate/VATabout, EDICOM, Sovos, and local law analyses (e.g. OneLegal). These provide the latest (as of Dec 2025) insight into Angola’s e-invoicing implementation. All regulatory references (Presidential Decree 71/25 and Exec. Decree 683/25) have been included via the secondary sources for accuracy. [kpmg.com], [kpmg.com] [ey.com], [ey.com] [vatabout.com], [vatabout.com]

See also

Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE

Latest Posts in "Angola"

Briefing document & Podcast: E-Invoicing in Angola

Latest Posts in "Angola"

Advertisements:

Contact:

Support & Info

Sign up for our newsletter