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Portugal

Briefing document & Podcast: E-Invoicing, E-Reporting and SAF-T requirements in Portugal

7 hours ago
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SUMMARY

Executive Summary:

Portugal has established a comprehensive digital VAT control system, combining mandatory e-invoicing for Business-to-Government (B2G) transactions, mandatory e-reporting for all VAT-registered businesses for all transactions, use of certified invoicing software for most businesses, granular electronic reporting (SAF-T) of transactions, and the introduction of pre-filled VAT returns. While B2G e-invoicing is mandated, Business-to-Business (B2B) and Business-to-Consumer (B2C) transactions can still use paper or PDF invoices, although electronic reporting of all transactions is still required. The system is evolving to align with the EU’s “VAT in the Digital Age” (ViDA) initiative, which aims for near-real-time digital reporting.

Key Themes and Ideas:

  • Mandatory E-Reporting: A key element of the Portuguese system is that all VAT registered businesses (including non-residents) must transmit invoice data electronically to the tax authority (AT) for all transactions (domestic and cross-border), even if the invoice itself is a paper or PDF document (for B2B and B2C). This is done using certified invoicing software that assigns an ATCUD and QR code to each invoice and reports the invoice details through SAF-T files.
  • E-Invoicing vs. E-Reporting: The documents clearly distinguish between e-invoicing and e-reporting: “E-invoicing refers to the issuance of invoices in a structured electronic format, while e-reporting involves electronically transmitting invoice data to the tax authority.” E-invoicing is mandatory for B2G, while e-reporting (electronically transmitting invoice data) is mandatory for virtually all VAT-registered businesses for all transactions.
  • B2G E-Invoicing Mandate: Since January 1, 2024, all suppliers to the Portuguese public sector, including SMEs, are required to issue e-invoices in a structured electronic format through the government’s FE-AP platform. Large companies were required to do this starting in 2021. The supported formats are CIUS-PT (XML), CEFACT CIUS-PT, and Peppol BIS 3.0.
  • SAF-T Reporting: The Standard Audit File for Tax (SAF-T) is central to Portugal’s e-reporting system. “The SAF-T (Standard Audit File for Tax) is an XML data format that companies must use to report transactions.” There are two main SAF-T schemas: one for billing (sales invoices) and one for accounting. The SAF-T file contains detailed data for each invoice, including “invoice number, date, customer tax ID, product/service codes, quantities, line item net amounts, VAT rates applied, VAT amount, and totals, as well as identifiers like ATCUD codes and timestamps.” The SAF-T Accounting file contains the full general ledger. The deadline for monthly SAF-T (PT) submissions for invoices is the 5th day of the following month.
  • ATCUD and QR Codes: “All invoices must include a unique code (ATCUD) and QR code for validation.” The ATCUD code is a unique 8-digit alphanumeric validation code obtained from the tax authority, ensuring the invoice was issued from certified software. The QR code encodes key invoice data and allows auditors or consumers to verify invoice details.
  • Qualified Electronic Signatures (QES): The requirement for Qualified Electronic Signatures (QES) on PDF invoices has been repeatedly postponed. As of late 2025, QES is expected to become mandatory on January 1, 2027. Until then, PDF invoices without QES are still acceptable. “From 2027, PDF invoices will only be considered valid electronic invoices if they include a Qualified Electronic Signature or Seal.”
  • Pre-Filled VAT Returns: Portugal has introduced pre-filled VAT returns for certain eligible businesses. “The system uses the transaction data already reported (through e-fatura/SAF-T) to generate a draft VAT return each period.” Eligibility is initially limited to Portuguese-established businesses that do not use cash-accounting, and whose purchase invoices are properly accounted for in the e-fatura system. Businesses with imports/exports are excluded from the pre-filled VAT return system at this time.
  • Penalties for Non-Compliance: Non-compliance with e-invoicing and e-reporting mandates can result in significant penalties. These include fines for failing to issue proper invoices (€150-€3,750), using non-certified billing software (€3,000-€18,750), and late or missing SAF-T submissions.
  • Alignment with EU ViDA: Portugal is actively aligning its systems with the EU VAT in the Digital Age (ViDA) initiative. “Portugal is actively preparing its e-invoicing and e-reporting framework to align with anticipated EU reforms by 2028–2030. The EU’s ViDA initiative will make structured e-invoicing the default by 2028 and require near-real-time digital reporting for intra-EU B2B transactions.”
  • Continued Evolution and Postponements: The implementation of e-invoicing and e-reporting rules is a continuous process, with deadlines frequently being postponed. Businesses need to remain vigilant about changes to the regulations. For example, as of October 2025, the mandate for QES on PDF invoices had been delayed several times.

Key Quotes:

  • “All invoicing by Portuguese businesses is subject to electronic reporting.”
  • “From 2027, PDF invoices will only be considered valid electronic invoices if they include a Qualified Electronic Signature or Seal.”
  • “The SAF-T (Standard Audit File for Tax) is an XML data format that companies must use to report transactions.”
  • “E-invoicing refers to the issuance of invoices in a structured electronic format, while e-reporting involves electronically transmitting invoice data to the tax authority.”
  • “Portugal is actively preparing its e-invoicing and e-reporting framework to align with anticipated EU reforms by 2028–2030.”

Implications for Businesses:

  • Businesses operating in Portugal must use certified invoicing software to generate invoices with ATCUD and QR codes.
  • All VAT-registered businesses must submit monthly SAF-T files containing detailed invoice data.
  • Suppliers to the public sector must comply with B2G e-invoicing requirements, using the specified electronic formats and the government platform.
  • Businesses should monitor updates regarding the mandatory QES requirement for PDF invoices.
  • Eligible businesses should take advantage of the pre-filled VAT return system to simplify compliance.
  • Monitor developments relating to the EU ViDA initiative, as Portugal will likely implement changes to align with these regulations.

 

INDEPTH ANALYSIS

E-Invoicing, E-Reporting, and SAF-T in Portugal – Comprehensive Overview
Timeline of Implementation (Past, Current, Future):
  • 2013: Portugal introduced mandatory electronic reporting of invoice data (e-Reporting) for resident VAT taxpayers. Since then, all resident businesses must submit sales invoice data to the tax authority (initially via a monthly SAF-T file). [sovos.com]
  • 2017–2019: Legal frameworks for e-invoicing were established. Law Decree 111-B/2017 set the stage for mandatory e-invoicing in public procurement (B2G). By April 2019, Portuguese public administrations had to be able to receive e-invoices from suppliers (aligning with EU Directive 2014/55). [sovos.com]
  • 2020: The government defined phased deadlines for the B2G e-invoicing mandate. (Notably, COVID-19 prompted some flexibility in 2020 to ease adoption of e-invoicing in public contracts.) [sovos.com]
  • 2021: B2G e-Invoicing began – Starting January 1, 2021, large companies supplying the public sector were required to issue electronic invoices to public authorities. Portugal also expanded the use of certified invoicing software for all businesses. All invoices must include a unique code (ATCUD) and QR code for validation. (Use of certified billing software had already been required for most companies, with thresholds lowered to €50k revenue by 2020.) [sovos.com]
  • 2022: The 2022 State Budget Law (published June 27, 2022) introduced digital VAT control measures. Key changes included new invoice content rules (the ATCUD code and QR code) and extended e-invoice reporting obligations to non-resident VAT registrants in Portugal from 2023. (Foreign businesses with a Portuguese VAT number now must follow the same e-invoicing software and reporting requirements as locals, effective Jan 1, 2023.) [sovos.com]
  • 2023: Full SAF-T integration was underway but deadlines were extended for practicality. The State Budget for 2024 (Law no. 82/2023, of Dec 29, 2023) postponed certain mandates: [garrigues.com]
    • The requirement for a Qualified Electronic Signature (QES) on all e-invoices was deferred – PDFs continued to count as “electronic invoices” through 2024. [fonoa.com], [garrigues.com]
    • The start of mandatory SAF-T Accounting submissions (annual comprehensive accounting data via SAF-T for the annual tax return) was delayed to fiscal periods from 2025 onward, meaning first submission in 2026. [fonoa.com], [garrigues.com]
  • 2024: B2G e-invoicing for all suppliers – As of January 1, 2024, small and medium enterprises must also issue e-invoices to public entities, completing the phased B2G mandate. The acceptance of PDF invoices without QES was extended through 2024 by the budget law. (In practice, this means during 2024 a simple PDF invoice is still valid, but this is temporary.) [sovos.com] [fonoa.com], [garrigues.com]
  • July 2025: Introduction of automatic pre-filled VAT returns for certain taxpayers (see details below). This marks a move to leverage e-reported data for easing compliance. [sovos.com]
  • January 1, 2025 (Planned): QES on e-invoices was originally expected to become mandatory. However, the 2025 State Budget Law (enacted late 2024) further postponed the QES mandate to Jan 1, 2026, and likewise pushed the periodic Accounting SAF-T go-live to 2027. Thus, throughout 2025, PDF invoices without a qualified signature remain acceptable. [sapeinvoice.com]
  • Current 2025 Update: A proposal in the 2026 Draft State Budget (Oct 2025) seeks to delay these mandates by another year. Under this proposal (pending approval), QES would become mandatory from Jan 1, 2027 (so PDF invoices remain valid through 2026), and the first periodic SAF-T Accounting submission would be due in 2028 (for FY2027 data). These delays aim to give businesses more transition time and align with upcoming EU requirements. [vatupdate.com], [vatupdate.com]
  • Future (EU VAT in the Digital Age – ViDA): Portugal is actively preparing its e-invoicing and e-reporting framework to align with anticipated EU reforms by 2028–2030. The EU’s ViDA initiative will make structured e-invoicing the default by 2028 and require near-real-time digital reporting for intra-EU B2B transactions. Portugal is expected to integrate real-time invoice reporting for cross-border B2B in line with these EU rules. By 2030, electronic invoicing and reporting will be the norm across the EU, and Portugal’s system (building on certified software, SAF-T, and e-invoicing mandates) is on track to meet those deadlines. [vatupdate.com]
Transactions Covered (Domestic, Cross-Border, B2B, B2C, B2G):
  • B2G (Business-to-Government): Mandatory e-Invoicing is in force for all public procurement. Large companies have been issuing structured e-invoices to government bodies since 2021, and as of 2024 this applies to all suppliers (including SMEs) for invoices to public entities. These B2G e-invoices must be in an approved electronic format and transmitted through the government platform. [sovos.com], [sovos.com]
  • Domestic B2B (Business-to-Business): There is currently no across-the-board mandate to issue electronic invoices in B2B private sector trade – paper or PDF invoices are still allowed in B2B and B2C commerce. However, Portugal monitors B2B transactions via e-reporting. All VAT-registered businesses (including non-residents registered for Portuguese VAT) are obliged to transmit their invoice data electronically to the Tax and Customs Authority (AT) for all transactions (domestic and cross-border). In practice, this means businesses must use certified invoicing software that assigns an ATCUD code and QR code to every invoice, and then report the invoice details to the tax authority’s system (either in real-time or via periodic SAF-T file). So while the invoice can be on paper/PDF (for now), the transaction data is electronically reported to the government. [sovos.com] [avalara.com]
  • B2C (Business-to-Consumer): Consumer sales invoices/receipts are generally not required to be sent to customers as e-invoices, but they must still be generated with certified software and included in the data reports to the tax authority. The requirement to include a QR code on all invoices (including B2C receipts) from 2021 aims to ensure even paper receipts are captured in the digital system. Thus, retail B2C transactions are within the e-reporting scope. Consumers can also see their invoices on the AT’s e-fatura portal, indicating that businesses are indeed reporting those sales.
  • Cross-Border Transactions: Both intra-EU and extra-EU transactions are subject to the invoice reporting mandate. Any invoice issued by a Portuguese taxpayer (or a foreign company registered in Portugal) – whether for a domestic deal or an export/intra-community supply – must be reported. At present, Portugal has not introduced a separate “clearance” e-invoicing system for cross-border sales; such invoices can be issued in the usual way (PDF or paper allowed), but the details go into the SAF-T report like any other sales. Looking ahead, EU rules may bring near-real-time reporting for intra-EU B2B invoices by 2028, which Portugal will incorporate (enhancing the current system for cross-border data). [avalara.com] [vatupdate.com]
  • Taxable Persons in Scope: All VAT-registered persons (established businesses and foreign traders with a Portuguese VAT number) are in scope for these mandates. Since 2023, foreign companies registered for Portuguese VAT are explicitly required to meet the same e-invoicing and e-reporting standards as local firms. There are very few exemptions – virtually every entity that must issue a VAT invoice in Portugal must use certified software and report via SAF-T. (One minor exemption: certain low-income taxpayers like small farmers under special schemes or very small businesses not obligated to issue invoices might be outside the certification requirement, but these are exceptions.) For B2G, any supplier (regardless of size or location) invoicing a Portuguese public entity must comply with the e-invoice requirement via the official platform. [sovos.com]
Data to be Provided (Content and Format Requirements):
  • Invoice Content: Portugal follows the EU VAT Directive’s standard invoice content, plus local specifics. Invoices must include all usual details: supplier and customer tax identification (NIF/VAT number), invoice date and sequential number, description of goods/services, quantity, unit price, taxable amount, VAT rate and amount for each rate, and total due. In addition, Portuguese invoices must show: [avalara.com], [avalara.com]
    • The ATCUD code – a unique validation code obtained from the tax authority for each series of invoices. This is an 8-digit alphanumeric code (comprised of a software certificate code and a document number) that must appear on every invoice to ensure it was issued from certified software.
    • A QR code – a two-dimensional barcode that encodes key invoice data (supplier NIF, ATCUD, invoice date, amounts, tax, etc.). Every paper or PDF invoice must include this QR code, which tax auditors or even consumers can scan to verify the invoice’s details in the AT system. (Taxpayers using certain EDI processes may be exempt from the QR code, as long as they report via SAF-T).
  • E-Invoice Format: For B2G e-invoicing, invoices must be issued in a structured electronic format compliant with the official standard. Portugal accepts the CIUS-PT format (a Portuguese implementation of the EU standard EN16931, in XML) and the CEFACT CIUS-PT format. In practice, the government’s e-invoicing platform uses the Peppol BIS 3.0 standard as well. Suppliers to public sector must upload/send an XML invoice through the central platform (FE-AP, managed by eSPap) in one of these formats. Each e-invoice must carry a qualified digital signature or seal to ensure authenticity and integrity (this is currently satisfied by system controls, with QES becoming explicitly mandatory soon – see below). E-invoices must be stored electronically for 10 years. [avalara.com] [sovos.com]
    • Note: For B2B and B2C, there is no prescribed e-invoice format because e-invoicing is optional. Many businesses use PDF or paper invoices. However, if they do use structured e-invoices, commonly the same XML standards (CIUS-PT/Peppol) could be used on a voluntary basis. The critical point is that from 2027, PDF invoices will only be considered valid electronic invoices if they include a Qualified Electronic Signature or Seal. This upcoming QES requirement means that, absent a structured e-invoice, a digitally signed PDF will be needed to meet the definition of an “electronic invoice” for tax purposes. [vatupdate.com]
  • E-Reporting Data (SAF-T files): The Standard Audit File for Tax (SAF-T) in Portugal is an XML data format that companies must use to report transactions. There are two main SAF-T schemas: one for billing (sales invoices) and one for accounting. For invoice reporting (SAF-T PT for billing), the file includes detailed data for each invoice issued: invoice number, date, customer tax ID, product/service codes, quantities, line item net amounts, VAT rates applied, VAT amount, and totals, as well as identifiers like ATCUD codes and timestamps. Essentially, it’s a complete electronic journal of all sales invoices and credit notes for the period. These monthly SAF-T (billing) files allow the tax authority to cross-check the reported sales against VAT returns and ensure no invoices are omitted. The SAF-T Accounting file (soon to be required annually) contains the full general ledger, including purchase invoices, payments, and journal entries, which is used for cross-validation of tax filings (e.g. annual financial statements and tax returns).
  • Data Transmission Methods: Businesses have options to send invoice data to the authorities: many use the monthly SAF-T file upload (covering all invoices of the month) via the tax portal. Alternatively, larger companies can opt for real-time web service reporting, transmitting each invoice directly to the tax authority’s system as it’s issued (Portugal’s system supports an API for immediate reporting, often used by retailers for each receipt). There’s also a manual entry option on the e-fatura web portal for very low volume issuers. Whichever method, the data content required is the same.
Deadlines for Data Submission (Reporting to Tax Authorities):
  • Sales Invoices (SAF-T Billing): The standard deadline for submitting the monthly SAF-T (PT) file for invoices is the 5th day of the month following the invoice date. (For example, January’s invoices must be reported by February 5.) There is a built-in grace period of a few days; no penalties apply if submission is made by the 8th of the month. This deadline has tightened over time (formerly the 12th of the month, moved earlier to improve “near-real-time” data). From January 2025, the 5th-day deadline becomes fully effective (the grace until the 12th is eliminated). In practice, many companies try to submit as early as possible in the month to ensure compliance. [EU+ ITx ne…Sept 2023]
  • Real-Time Reporting: If using the real-time web service to report invoices individually, each invoice’s data is transmitted almost immediately upon issuance. The law effectively deems those reported as compliant with the monthly submission requirement. (Businesses must still ensure all invoices end up reported by the monthly cutoff if any were missed in real-time.)
  • B2G E-Invoices: Invoices to public entities generally must be delivered through the government platform at the time of issuance (or very shortly after, following any specific contract terms). Public contracts usually require suppliers to send the e-invoice via the FE-AP/Peppol network soon after supplying the goods or services. In any case, those invoices will also appear in the SAF-T monthly file, but timeliness in issuance is mandated by public procurement rules.
  • Annual SAF-T Accounting: Starting with fiscal year 2025, companies will need to submit their annual accounting SAF-T file together with or prior to the annual tax return (“IES” – Annual Business Statement). This was postponed but is slated to apply for 2025 onward. Typically, the annual return (and thus the SAF-T accounting file) is due by mid-2026 for FY2025. (The exact due date will align with the annual tax filing deadline, usually by June or July of the following year.) [garrigues.com]
  • Other Obligations: Portugal also has a real-time reporting requirement for transport documents (shipping of goods), where details must be sent to the tax authority before goods move. This is a separate mandate ensuring e-reporting of dispatch notes. Additionally, inventory reports are required annually (though inventory valuation requirements have been temporarily waived for 2023–24). These are part of the broader e-reporting landscape, though not directly about invoicing. [garrigues.com], [garrigues.com]
  • VAT Return Filing Frequency: (Not asked, but to clarify context) Most companies file VAT returns monthly or quarterly, and the e-invoice data reporting is effectively a separate obligation. The introduction of pre-filled returns in 2025 (see below) ties these together by using the reported data for the return preparation.
Penalties for Non-Compliance:
Portugal imposes administrative fines for failures in invoicing and reporting compliance. Key penalty areas include:
  • Failure to Issue Proper Invoices: Not issuing an invoice, or issuing one that lacks required information (including the ATCUD/QR code or proper format), can trigger fines. For example, failing to issue a legally compliant invoice can result in fines roughly ranging from €150 up to €3,750 per infraction. This would cover scenarios like not using e-invoicing when required (e.g., a supplier not sending a B2G e-invoice) or not including mandated content on the invoice. [avalara.com]
  • Not Using Certified Software: Using non-certified billing systems or modifying invoice sequences unlawfully is taken seriously. Fines for using unapproved invoicing software range from about €3,000 up to €18,750, reflecting the tax authority’s focus on preventing fraud through software certification. Each invoice issued outside a certified system could be considered a violation. [avalara.com]
  • Late or Missing SAF-T Submissions: If a taxpayer fails to submit the monthly SAF-T file by the deadline (or at all), the tax authority can levy fines as well. While specific amounts aren’t explicitly published in the sources above, these would fall under general tax infraction penalties. In practice, the AT has given leniency during transitions (e.g., no fines for late SAF-T until after the grace period each month). Now that deadlines are established by law, persistent non-compliance could lead to fines likely in the few hundred euros per filing, and potentially higher for repeated offenses. [EU+ ITx ne…Sept 2023]
  • Other Sanctions: Businesses that do not comply may also face indirect consequences – e.g., inability to use certain simplified regimes, audits, or in serious cases, the tax authority can invalidate undeclared invoices (affecting VAT recovery). However, for most cases, monetary fines as listed are the primary penalty.
  • References: These penalty ranges are codified in Portugal’s General Regime for Tax Infractions. The specific amounts cited (€150–€3,750 for invoice issues and up to €18,750 for software violations) are drawn from official guidance. It’s worth noting that Portuguese authorities often incrementally enforce these changes; initial non-compliance might get a warning, but as the system matures, fines will apply more strictly. [avalara.com]
Format of E-Invoices and Reports:
  • E-Invoice Format: Portugal adheres to EU standards. For B2G, the format must be CIUS-PT (XML), which is a country-specific UBL schema, or the CEFACT CIUS-PT format. Both are XML-based and compliant with EN16931 (European e-invoice standard). These can be transmitted via the Peppol network using Peppol BIS 3.0 specifications, as eSPap (the Portuguese public sector shared services) acts as a Peppol Authority. In practice, this means suppliers can use a Peppol Access Point to send invoices to the government. Each e-invoice must include a digital signature (and soon a QES) to ensure authenticity. [avalara.com] [sovos.com]
  • PDF/Paper Invoices: Outside B2G, invoices can be PDF or paper, but to count as “electronic” for tax purposes going forward, a PDF will need a Qualified Electronic Signature or Seal from an EU-certified provider. This requirement, scheduled for 2025 and now delayed to 2026/27, is meant to ensure document integrity. Until that takes effect, PDFs (even without signature) are accepted as valid invoice documents (as an interim measure extended through 2025). All paper/PDF invoices must carry the printed QR code and ATCUD, linking them to the digital data reported. [vatupdate.com] [sapeinvoice.com]
  • SAF-T File Format: The SAF-T (PT) file is an XML format defined by the Portuguese tax authority. The schema is based on the OECD SAF-T standard adapted for Portugal. For billing, the file (often named SAFTPT_enviado_AAAAMMDD.xml) contains structured fields for master data (customer, product, tax code tables) and for each invoice/credit note. It’s generated by certified software or ERP systems and uploaded to the tax portal. For accounting, the SAF-T file includes general ledger accounts, journal entries, and trial balance data. These files must be prepared in exact XML format as per the law (portaria that approved SAF-T PT schema) and typically must pass validation on the tax authority’s system.
  • Government Portals: Electronic transmission is done through the e-fatura platform (the official online system). Businesses either upload the SAF-T file in their e-fatura account or integrate via web services. The FE-AP platform is used for B2G invoice submission (often via Peppol), while e-fatura is used for reporting and for pre-filled return checks.
  • Summary: In essence, Portugal’s framework uses structured data formats end-to-end: Invoices themselves (for B2G and possibly B2B in the future) follow an XML standard; invoice data is reported via XML (SAF-T); even printed invoices include codes to tie back to the electronic record. This structured approach sets the stage for automation like pre-filled returns and EU-wide data exchange.
Pre-Filled VAT Returns (Automatic VAT Returns):
Yes – Portugal has introduced pre-filled (“automatic”) VAT returns recently, leveraging the e-invoice data collected. As of 1 July 2025, the Tax and Customs Authority (Autoridade Tributária, AT) began offering an “Automatic VAT Return” (Declaração Periódica Automática) for certain taxpayers. Key points: [sovos.com]
  • The system uses the transaction data already reported (through e-fatura/SAF-T) to generate a draft VAT return each period. Essentially, the AT pre-populates the VAT sales and purchase amounts based on invoices it has on file. [sovos.com]
  • Who is eligible: Initially, this is available only to Portuguese-established businesses that meet specific conditions. The business must be resident in Portugal, not use the cash-accounting scheme for VAT (i.e. must be on normal accrual method), and the business must have all its purchase invoices properly accounted for in the e-fatura system (meaning suppliers have reported them and the company has classified them online). Essentially, the company’s entire input/output VAT data needs to be in the AT’s databases. [sovos.com]
  • Exclusions: Even eligible businesses will be excluded in periods where they have certain transactions that complicate the return. Notably, if the company has imports or exports, or other cross-border dealings in that period, the automatic return won’t cover those (such businesses are excluded from the program). Also, any period with reverse-charge operations or special regimes is excluded. Additionally, if a purchase invoice was not digitally reported by the supplier and the buyer had to manually add it in e-fatura, that invoice won’t be picked up for the pre-fill (to avoid mistakes). In short, the system currently targets straightforward domestic-only activity. [sovos.com]
  • How it works: For those in scope, the tax authority generates a provisional VAT return each filing period (monthly or quarterly as applicable). Taxpayers access it via the e-fatura portal. The return is pre-filled with sales and purchase figures and the resulting VAT due or credit. The taxpayer reviews the draft, makes any necessary corrections or additions (if something was missing or incorrect), and then submits it as the official return. If the taxpayer had no activity in that period, the system can even submit a nil return automatically. This automation aims to reduce errors and compliance burden. [sovos.com]
  • Impact: This pre-filled return initiative is one of the outcomes of having comprehensive e-invoicing and e-reporting data. By cross-checking what all suppliers and customers report, the tax authority can largely compute a business’s VAT position. However, it’s still new – businesses need to verify the pre-filled data. It does not yet apply to all companies, but Portugal is expected to expand it once the system proves reliable. It’s also noteworthy that as EU moves towards transactional reporting, such pre-filled returns (already seen in Italy, Spain, etc.) will become common; Portugal is among the early adopters of this approach.
Relevant Regulations & Official Resources:
  • Public e-Invoicing Legislation: Law Decree No. 111-B/2017 (and subsequent amendments like Law 123/2018) set out the B2G e-invoice mandate. The official platform is managed by eSPap under the Ministério das Finanças. More info is available on the government’s ESPAP website and the Portuguese Finance Portal (Portal das Finanças). [sovos.com]
  • Tax Code & SAF-T Ordinances: The requirement to use certified billing software and report via SAF-T is regulated by Portaria (Ordinance) No. 302/2016 (which approved the SAF-T (PT) schema) and Portaria 195/2020 (which introduced the QR code and ATCUD rules). The monthly SAF-T deadline change to day 5 was made by Portaria 351/2021. Official info (in Portuguese) can be found on the Portal das Finanças – for instance, the 2024 State Budget Law (Law 82/2023) and the explanatory notes from the tax authority. [garrigues.com], [garrigues.com]
  • Recent Budget Laws: The State Budget 2024 law (Lei n.º 82/2023) and State Budget 2025 law (once enacted) detail the postponements of QES and SAF-T accounting obligations. The government often publishes “Dispatches” or official notices extending deadlines (e.g., acceptance of PDF invoices) – e.g., Despacho 8/2022-XXIII mentioned in Garrigues. [garrigues.com], [sapeinvoice.com] [garrigues.com]
  • Ordinance on Automatic VAT Return: Ordinance No. 242/2025 (of 29 May 2025) established the criteria for the automatic VAT return system. This was published in the official gazette Diário da República. It spells out the taxpayer scope (residents, not on cash accounting, etc.) for the pre-filled returns program. The AT’s e-fatura portal (official site: e-fatura.gov.pt) provides guidance and FAQs on the automatic return feature. [pwc.pt]
  • Government Portals: Key official resources include the Portal das Finanças (info.portaldasfinancas.gov.pt) – which hosts legislation, and the E-invoice/FE-AP Portal for B2G (feap.gov.pt). The tax authority also issues circulars (e.g., Circular No. 30213/2021 for QR code requirements, Circular 25066 of 2025 for the automatic VAT return introduction).
  • External References: Reputable tax technology firms monitor these changes. For example, Fonoa and Sovos have published updates on Portugal’s e-invoicing postponements, and Big 4 firms like PwC Portugal have issued client alerts (e.g., PwC’s flash news on Ordinance 242/2025). These can be useful for detailed commentary on implementation. [fonoa.com], [vatupdate.com] [pwc.pt]
Conclusion:
Portugal has one of the more advanced digital VAT control systems in Europe, combining mandatory e-invoicing for government clients, certified invoice software for all businesses, granular e-reporting (SAF-T) for transactions, and now even automatic VAT return filing. The implementation has been phased in over many years – starting with early SAF-T adoption in 2008, up through the latest 2025/2026 deadlines. As of today, all invoicing by Portuguese businesses is subject to electronic reporting, and B2G invoicing must be fully electronic. The system will continue to evolve, especially as EU-wide e-invoicing and real-time reporting standards emerge by 2028. Companies operating in Portugal should ensure they use authorized invoicing systems, adhere to the reporting deadlines, and keep an eye on the upcoming QES signature requirement by 2026/27. Compliance is rewarded with a simpler tax life (e.g. pre-filled returns), whereas non-compliance can lead to financial penalties. All these measures aim to increase tax transparency, reduce VAT fraud, and streamline tax administration in Portugal. The trend is clearly toward fully digital tax reporting, so businesses should treat electronic invoicing and reporting not as a mere formality, but as an integral part of their accounting processes. [vatupdate.com] [avalara.com] [EU+ ITx ne…Sept 2023], [EU+ ITx ne…Sept 2023]

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