Return to mapElectronic invoicing and e-Reporting in Portugal
Electronic invoicing in Portugal has become a key tool in modernizing the administrative processes of the public sector. Its mandatory adoption began to take shape with the publication of Decree-Law 111-B/2017, which transposed Directive 2014/55/EU into the Portuguese legal framework.
Characteristics of Electronic Invoicing in Portugal
Portugal has made significant progress in implementing electronic invoicing through a centralized model coordinated by the Entidade de Serviços Partilhados da Administração Pública (eSPAP), which promotes interoperability and ensures efficiency in the exchange of documents between suppliers and public administrations.
The competent authority in tax matters is the Autoridade Tributária e Aduaneira (AT), the body responsible for overseeing and regulating tax compliance in Portugal.
Mandatory Use
The use of electronic invoicing is mandatory in B2G relations, meaning between suppliers and public administrations. In the B2B sphere (between private companies), its adoption is optional, allowing each entity to assess and decide on its implementation according to its technological and operational needs.
Invoice Format
For issuing invoices addressed to public administrations, the valid electronic formats are:
- UBL 2.1 “CIUS-PT”
- CEFACT “CIUS-PT”
Both schemas are based on XML language and adapted to national specifications to guarantee interoperability.
Electronic Signature
In Portugal, an electronic signature is a mandatory requirement for all invoices issued to public administrations. This requirement aims to ensure the authenticity of origin and the integrity of the electronic document’s content, in accordance with national legislation and European regulations on electronic invoicing.
The signature must be applied by the issuer of the invoice using a qualified digital certificate issued by a recognized certification authority, in compliance with Regulation (EU) No. 910/2014 (eIDAS) on electronic identification and trust services. This regulation establishes a common framework ensuring that electronic signatures are valid and recognized across all European Union Member States.
Invoice Archiving
Portuguese regulations require that electronic invoices be retained for a minimum period of 10 years by both the issuer and the recipient. This storage must guarantee the integrity, authenticity, and accessibility of the documents over time.
Administrative Requirements
Suppliers issuing invoices to public entities integrated with the eSPAP portal are required to register in the system and complete connection tests to ensure interoperability. In contrast, suppliers working with public administrations not integrated with eSPAP must connect to each entity’s specific portals, adapting to their particular technical requirements.
Upcoming dates in Portugal
Electronic Tax Filing through SAF-T in Portugal
Portugal was one of the pioneer countries in adopting the SAF-T (Standard Audit File for Tax) system, introduced in 2008 to automate and centralize the electronic submission of tax, accounting, and transport information. This obligation applies to all companies headquartered or with a permanent establishment in the country that are subject to Corporate Income Tax (IRC) or Personal Income Tax (IRS) and that maintain organized accounting.
The regulations require the use of three types of electronic files in SAF-T PT format, each with different requirements and periodicities:
SAF-T PT for Invoicing
This file contains the necessary data for the electronic VAT declaration and must be submitted before the 5th of each month. It includes detailed information such as the header, client data, tax table, issued invoices, and received payments. Files must be generated sequentially, and the creation process must integrate the electronic signature of the previous invoice as a control and integrity mechanism.
SAF-T PT for Electronic Accounting
The electronic accounting file collects the company’s financial and accounting data. It must be submitted monthly or annually, depending on the company’s tax regime, and must include elements such as the header, the chart of accounts, client and supplier tables, the tax table, accounting transactions, and payment receipts, where applicable. It serves as a key tool for ensuring the transparency and traceability of economic operations.
Communication of Electronic Transport Documents
VAT taxpayers are required to electronically communicate transport documents related to the movement of goods before their execution. The Autoridade Tributária e Aduaneira (AT) issues a validation code that must be included in the document as authorization for the movement of goods. This system allows for real-time monitoring of goods transportation and strengthens the fight against tax fraud.
EDICOM Solution for SAF-T PT
EDICOM’s solution is certified by the Autoridade Tributária e Aduaneira of Portugal, in accordance with Portarias No. 363/2010 and 340/2013, and fully automates the process of generating, transmitting, and storing SAF-T files.
- Data Capture: integration with the ERP to extract tax and accounting information.
- File Generation: automatic structuring of data according to the SAF-T PT format.
- Connectivity: direct file transmission to the tax authority through a secure communications HUB.
- Integration and Traceability: monitoring the status of transmissions from the management system.
- eIDAS-compliant Archiving: secure electronic archiving during the legal retention period.
- Multilingual Support: specialized assistance to resolve any technical or regulatory issues.
This solution enables companies to meet their tax obligations in Portugal in a secure, automated, and legally compliant manner.
Upcoming dates in Portugal
Frequently Asked Questions
As companies adopt electronic invoicing as the only invoicing system, it is natural that questions and doubts arise about its implementation. In this context, we aim to address some of the most common questions related to B2G electronic invoicing in Portugal.
When is it Mandatory to Send Electronic Invoices in Portugal?
Currently, electronic invoicing is mandatory for all companies that need to invoice public sector administrations in Portugal. The electronic invoicing regulations came into effect in April 2020 and have gradually expanded to encompass all Portuguese companies, also impacting suppliers from other countries.
What is the electronic invoicing system like in Portugal?
The electronic invoicing system in Portugal is decentralized. This means that, unlike other countries, public administrations in Portugal can choose the electronic invoicing solution that best suits their needs, as long as they comply with the electronic invoice formats and standards established by local regulations.
What is the role of eSPAP in the electronic invoicing project in Portugal?
eSPAP provides a solution (Portal FE-AP) for the implementation of the electronic model in Portugal, enabling a communication channel for sending invoices to public administrations and government agencies. Public institutes and the direct government administration will use this platform as a channel to receive invoices from their suppliers. Other public entities will be able to join the eSPAP service on a voluntary basis, although they can decide to implement their own communication channels based on their specific needs.
What is the Portal FE-AP?
It is the portal for electronic invoicing the Public Administration developed by eSPAP with the aim of becoming the entry point for receiving electronic invoices from the Public Administration.
What are the main features of the eSPAP electronic invoicing solution?
It offers public administrations connected to the eSPAP platform the ability to receive electronic invoices from their suppliers through the eSPAP platform and provides mechanisms for monitoring, validation, and processing in their own accounting systems.
Are Portuguese administrations ready to receive electronic invoices?
Public administrations and institutions had until April 18, 2020, to adapt their information systems to the electronic invoicing model. Since then, the Portuguese public administration is prepared to receive electronic invoices in accordance with the B2G electronic invoicing project.
What is eSPAP?
eSPAP - Entidade de Serviços Partilhados da Administração Pública (Shared Services Entity of Public Administration) coordinates the implementation of the Electronic Invoice in the Public Administration. The Decree 123/2018, dated December 20, grants eSPAP all the power to regulate the technical and functional requirements for the implementation of electronic invoicing with public administrations in Portugal.
Which public entities are required to use the eSPAP platform?
The organizations obligated to connect to eSPAP to receive electronic invoices are those managed by the government and public institutes. Other local public entities, such as hospitals, municipalities, courts, etc., may choose to develop their platform.
How do I send my invoices? Via email, through a portal, or...?
In the case of public administrations and public institutes, which are mandated to use the eSPAP platform, there are two options. The first is to automatically send invoices to this platform via the Web Service protocol. Alternatively, there is the option to manually submit invoices through a portal provided by eSPAP, which is often more commonly used by taxpayers with lower invoice volumes. The other administrations can decide which platform to use, whether eSPAP or any other system.
Upcoming dates in Portugal
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