Updated on February 29th, 2024

When Portugal adopted the EU e-invoicing Directive 2014/55/EU on April 16th, 2014, it became understood that business-to-government (B2G) e-invoicing would become mandatory throughout the country. State and public authorities have to use eSPap’s platform to receive invoices. Vendors must use UBL 2.1 CIUS-PT or CEFACT CIUS-PT to send signed e-invoices. To provide you with the most up-to-date information, below you can find the latest published deadlines, information about the national coordinating body, the Portuguese invoice standard, and more.  

eSPap and the Invoice Standard Known as CIUS-PT 

eSPap (Entidade de Serviços Partilhados da Administração Pública) is the coordinating body for the implementation of electronic invoicing (e-invoicing) in Portugal. With Legislative Decree 123/2018 from December 28th, 2018, eSPap was granted the authority to do the following: 

  • Set technical and functional requirements to support e-invoicing implementation 
  • Develop support tools for involved parties 
  • Provide a solution for receiving and processing e-invoices 

Unlike many other countries in the European Union, Portugal does not have a national Peppol authority. In situations like this, when there is no national Peppol authority in a country, OpenPeppol AISBL acts as the authority.  

The accepted invoice formats for B2G e-invoicing in Portugal are UBL 2.1 'CIUS-PT' and CEFACT 'CIUS-PT'. These invoice formats comply with the European Standard EN 16931-1. 

FE-AP and B2AP 

The implementation of the so-called Electronic Invoice Solution in Public Administration is based on two solutions for electronic invoicing: 

  • Business to AP (B2AP): This portal is for suppliers to government agencies to monitor electronic invoice delivery and status (in a pilot phase) 
  • Electronic Invoicing Portal for Public Administration (FE-AP): This portal is for government agencies with the purpose of invoice receipt and verification (in production) 

The FE-AP solution has been piloted by three clients of the GeRFiP solution and is now gradually being distributed to public entities. The FE-AP offers the possibility of receiving invoices and correcting documents in an electronic format, ensuring control and supervision at all stages of the process. This solution is available to any public entity and offers direct integration with the GeRFiFiP solution, as well as with web services or any other accounting or document management system.  

Key Deadlines and Compliance  

Portugal was one of the first countries to meet the deadline set forth by the European Union. In fact, Portuguese government agencies have been able to receive e-invoices since April 18th, 2019. However, as mentioned above, Portugal is mandating e-invoicing in phases, the next of which is to enforce government suppliers to send electronic invoices.  

But that’s not all. For different types of companies (defined by the European Commission (Recommendation 2003/361/EC)), different deadlines apply: 

  • LARGE ENTERPRISES, those which employ more than 250 people or have an annual turnover of more than EUR 50 million or have an annual balance sheet total of more than EUR 43 million, there is an obligation to send e-invoices from January 1st, 2021 
  • MID-SIZE ENTERPRISES, those which employ fewer than 250 people and their annual turnover does not exceed EUR 50 million and/or their annual balance sheet total does not exceed EUR 43 million, it is mandatory to send e-invoices from July 1st, 2021 
  • SMALL ENTERPRISES, those with fewer than 50 employees with an annual turnover and/or an annual balance sheet total of no more than EUR 10 million, it is mandatory to send e-invoices from July 1st, 2021 
  • MICRO-ENTERPRISES, those with fewer than 10 employees with an annual turnover and/or an annual balance sheet total of no more than EUR 2 million, it is mandatory to send e-invoices from January 1st, 2022 

E-invoice Requirements Portugal

Each e-invoice must have the following:

  • Unique invoice identifier (transmission date, company information, and recipient)
  • QR code as of 1st January 2022
  • ATCUD as of January 1st, 2023
  • An electronic signature in electronic invoices in PDF format to ensure they are valid as from 1st July 2022.

Companies should have a system that verifies the signature’s validity as of July 31, 2022. The Autoridade Tributária e Aduanera (AT) must certify a system or software solution for companies to add the ATCUD and the QR code.

ATCUD is a unique ID number in an invoice and is a fragment of the information of the QR code. The ATCUD number has the following format; ATCUD: Validation Code-Sequential number.

Taxpayers get the first part of the ATCUD (validation code) by communicating the document series to the AT. The taxpayer must also give other items such as type of document and first document number of the series. Afterward, AT delivers a validation code that is valid for at least a fiscal year for the whole document series. The sequential number (second part of the ATCUD) is the number that follows within the document series.

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