Regulatory updates - Portugal
Get the latest news and updates on e-invoicing, e-ordering, e-archiving and indirect tax regulatory requirements.
Portugal postpones e-invoicing and QES requirements to 2025
On 29 November 2023, the Portuguese State Budget Law for 2024 was approved with another postponement of regulations for electronic invoices for B2G and qualified electronic signatures (QES) for PDFs.
SMEs have been given an extension to adhere to the e-invoice mandate
SMEs and micro enterprises will not have to comply with e-invoicing obligations until 1 January 2024
B2G e-invoicing obligation postponed for micro businesses and SMEs
On 18 May 2023, The Council of Ministers released a Communiqué, announcing the approval of the decree-law amending the rules for implementing the State Budget for 2023.
PDF will be considered an e-invoice until 31 December 2023
The Portuguese government extended the validity of PDF invoices as electronic invoices for one more year.
Portugal postpones e-signature requirements once again
The Portuguese government has announced another delay for e-signature on PDF invoices requirement to enter into force.
ATCUD unique identifier becomes optional to include in tax-relevant documents
Documentation on how to submit the document series in order to get the validation codes to generate the ATCUD number is now available under the Portuguese Tax Authority website.
E-signature requirement for PDF invoices (QES) postponed until 1 July 2022
The validity of PDFs as electronic invoices has been extended again until 30 June 2022, according to Dispatch 351/2021-XXII. Therefore, the QES (Qualified Electronic Signature) will have to be applied on PDFs and all non-EDI invoices as of 1 July 2022.
Requirement for ATCUD is suspended until 2023
According to Dispatch N. 412/2020 XXII, the ATCUD number was supposed to be mandatory on invoices and all other fiscal relevant documents from 1 January 2022. However, with the new budget proposal for 2022, this requirement has been suspended.
Further postponement of the QES application requirement to PDF invoices in Portugal
The validity of PDFs as electronic invoices has been extended again until 31 December 2021. Therefore, the QES (Qualified Electronic Signature) will have to be applied on PDFs as of 1 January 2022.
Portugal postpones the requirement to apply QES to PDF invoices
The Portuguese government keeps on introducing measures to relieve taxpayers of the negative effects of the COVID-19 pandemic. One of them is another postponement of the deadline for mandatory application of QES (Qualified Electronic Signature) on PDF invoices for tax purposes.
Country specifications
E-Invoicing/CTC Model:
– B2G: Centralised
– B2B: Post-Audit
Mandatory Infrastructure:
– B2G: FEAP
– B2B: N/A
Mandatory Format:
– B2G: CIUS PT
– B2B: N/A
Mandatory for Issuing:
– B2G: Gradual rollout for suppliers to all contracting authorities, from January 2021
-SMEs must send only e-invoices from 1 January 2025
– B2B: No explicit requirements
Mandatory for Receiving:
– B2G: All contracting authorities
– B2B: Buyer’s consent required
eSignature:
Required in non EDI invoices (PDF, etc.); effective – 1 January 2025
Archiving Period:
10 years
Archiving Abroad:
Allowed under conditions
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