Portugal is the most misunderstood e-invoicing jurisdiction in Europe, including by businesses already operating there. The country has, strictly speaking, no general B2B e-invoicing mandate. There is no SDI-style clearance platform, no Peppol B2B obligation, no real-time invoice approval workflow. And yet Portugal’s digital tax stack is among the most demanding in Europe. Every invoice, paper, PDF, or XML, must be issued by AT-certified software, carry an ATCUD code, display a QR code, and feed into a monthly SAF-T (PT) Billing file submitted to the tax authority by the fifth of the following month.
From 1 January 2027, every PDF invoice issued in B2B or B2C will additionally require a Qualified Electronic Signature (QES). What looks like “no e-invoicing mandate” is actually a layered post-issuance reporting model that achieves much of what other countries achieve through clearance, without the clearance step itself.
This article walks through the four compliance layers a business operating in Portugal needs to understand: the certified-software regime, the ATCUD and QR code obligations, the SAF-T reporting layer, and the B2G e-invoicing mandate. Each layer is independently enforceable. None is optional. The architecture is unusual enough that misunderstanding it is the single most common cause of Portuguese tax compliance failures among foreign-headquartered businesses.
Before getting into the technical detail, it helps to separate the layers a business in Portugal operates under. Each has its own legal basis, its own deadline, and its own penalty regime:
- Layer 1: AT software certification (Modelo 24). Every invoicing program used in Portugal must be certified by the Autoridade Tributária e Aduaneira (AT) under Portaria 363/2010, as updated by subsequent regulations. The certified software’s number must appear on every invoice. Non-certified software carries fines of €3,000–€18,750 per infraction.
- Layer 2: ATCUD and QR code. Since 1 January 2022 (QR code) and 1 January 2023 (ATCUD), every invoice issued by certified software must display a unique document code (ATCUD = “ValidationCode-DocumentNumber”) and a QR code encoding the invoice data per the AT specification.
- Layer 3: SAF-T (PT) reporting. SAF-T Billing is submitted monthly by the fifth day of the following month, covering all invoices issued. SAF-T Accounting becomes mandatory from 2028 (for FY 2027 and onward) under the latest 2026 State Budget deferral.
- Layer 4: B2G e-invoicing in CIUS-PT. Mandatory for large companies since January 2021, extended to small, medium, and micro enterprises from 1 January 2026. Suppliers to public bodies must issue structured XML invoices in CIUS-PT format (UBL 2.1 or CEFACT) through the eSPap-operated FE-AP platform or another approved channel.
- Layer 5: Qualified Electronic Signature on PDF (planned, 1 January 2027). Under the 2026 State Budget (approved 27 November 2025), the QES requirement for PDF invoices in B2B and B2C transactions has been deferred to 1 January 2027. Until 31 December 2026, PDF invoices issued by certified software with ATCUD and QR code remain valid without QES.
Each layer applies independently. Compliance with Layer 4 does not exempt a business from Layers 1–3. Compliance with Layers 1–3 does not exempt a B2G supplier from Layer 4.
What is E-Invoicing in Portugal?
E-invoicing in Portugal does not mean what it means in Italy, France, or Romania. There is no centralised clearance platform that approves invoices before they are sent. Instead, Portugal operates a post-issuance reporting model: the invoice is issued by certified software, delivered to the buyer through whatever channel the parties agree (PDF email, EDI, structured XML, paper), and the data is communicated to AT after the fact through SAF-T Billing or real-time webservice submission. The AT does not pre-approve invoices; it audits the population of issued invoices through the structured data feed.
The supervising authority is the Autoridade Tributária e Aduaneira (AT), Portugal’s tax authority, which administers software certification (via Modelo 24), the ATCUD series registration system, the SAF-T (PT) framework, and the e-Fatura reporting portal. For the B2G sub-regime, eSPap (Entidade de Serviços Partilhados da Administração Pública) is the Portuguese Peppol Authority and operator of the FE-AP (Fatura Eletrónica à Administração Pública) platform that receives invoices destined for public administration.
What is B2B e-invoicing in Portugal?
B2B e-invoicing in Portugal is voluntary in format but mandatory in process. There is no obligation for the parties to exchange invoices in structured XML. PDF invoices are valid e-invoices under Portuguese law and will remain so until 31 December 2026. EDI invoices are valid. Paper invoices are valid. What is not optional is the process around the invoice: it must be issued by AT-certified software, it must carry ATCUD and QR code, and its data must reach AT through SAF-T Billing by the fifth of the following month.
A common misconception in client conversations: people see “ATCUD on the invoice” and assume that alone makes the document valid. It does not. An invoice with an ATCUD but produced by non-certified software is not a valid Portuguese invoice, the ATCUD must come from a certified system that is also producing the hash chain and feeding SAF-T. This is the most operationally important point in the entire Portuguese stack. The integrity-and-authenticity requirement of CIVA Article 233 (Portugal’s VAT Code, mirroring EU VAT Directive Article 233) is satisfied by certified software + hash chain + ATCUD/QR + monthly SAF-T reporting, collectively. Removing any one element invalidates the invoice.
From 1 January 2027, the regulators are adding a fifth element specifically for PDF invoices: a Qualified Electronic Signature (QES) issued by an EU-listed trust service provider. The other four elements (certified software, ATCUD, QR, hash chain, monthly SAF-T) do not go away, QES is added on top, specifically because Portugal recognises that PDFs, unlike structured XML, can be altered after issuance unless cryptographically sealed.
What is B2G e-invoicing in Portugal?
B2G e-invoicing is a true structured-format mandate in Portugal, and it is one of the most operationally active e-invoicing regimes in Southern Europe. The legal basis is Lei n.º 111-B/2017 (transposing EU Directive 2014/55/EU) and subsequent amendments through Lei n.º 82/2023. The format is CIUS-PT, the Portuguese Core Invoice Usage Specification under EN 16931, implemented as UBL 2.1 or CEFACT XML. Two channels are accepted: the centralised FE-AP platform operated by eSPap, or other certified channels (web services, AS2, third-party portals, Peppol via accredited Access Points).
The B2G rollout has been gradual and is approaching completion:
- Large enterprises: mandatory since January 2021.
- Small, medium, and micro enterprises: mandatory from 1 January 2026 (after multiple postponements).
- Public administrations: obligated to receive and process structured e-invoices since 18 April 2019.
Suppliers issuing fewer than 250 invoices per year to public bodies can use the FE-AP Microportal for manual upload; higher volumes require web service or AS2 integration. Some public entities operate their own portals and may impose specific transmission requirements.
What is B2C e-invoicing in Portugal?
There is no B2C structured invoicing mandate in Portugal. Consumers may receive paper invoices, PDF invoices, or, if the merchant chooses, structured electronic invoices. The same four-layer compliance stack that applies to B2B (certified software, ATCUD, QR code, SAF-T reporting) also applies to B2C: a retailer issuing till receipts is using certified POS software, the receipt carries a QR code that consumers can scan into the e-Fatura portal to claim VAT deductions, and the receipt data flows into SAF-T Billing monthly.
From 1 January 2027, the QES requirement for PDF invoices also applies to B2C, meaning that a business issuing a PDF receipt to a consumer will need to apply a QES, unless it issues the document in CIUS-PT structured format or through a certified EDI system. This should be described carefully: paper receipts remain valid and do not require a QES. The QES obligation attaches specifically to electronic documents in PDF or similar unstructured format.
E-Invoicing in Portugal 2026 Last Updates
The defining 2026 development is the 27 November 2025 approval of the 2026 State Budget by the Portuguese Parliament (Draft Law No. 37/XVII/1), which formally extended two of the most consequential deadlines in Portugal’s digital tax roadmap:
- PDF as valid e-invoice extended through 31 December 2026. The transitional regime under which PDF invoices issued by certified software with ATCUD and QR code count as valid electronic invoices, without a QES, has been extended by one year. The QES requirement now applies from 1 January 2027.
- SAF-T Accounting deferred to 2028. The first mandatory annual SAF-T Accounting file submission now applies to FY 2027 transactions, with filing in 2028. Under the previous schedule, FY 2026 transactions were due in 2027. The annual SAF-T Accounting layer is now firmly out of the 2026–2027 operational window.
Three other 2026 developments worth tracking:
- B2G mandate for SMEs and micro-enterprises went live on 1 January 2026. After multiple postponements, the small, medium, and micro-enterprise B2G mandate is now in force. Every supplier to Portuguese public administration must issue CIUS-PT structured invoices, regardless of size.
- Non-resident VAT-registered businesses are squarely in scope. Since 1 January 2023, foreign businesses VAT-registered in Portugal are subject to the same three core requirements as residents: certified invoicing software, ATCUD code, and QR code on every invoice. Several jurisdictional clarifications have continued through 2025–2026 confirming that there is no “foreign company” exemption.
- Portugal is preparing for ViDA. The Secretary of State for Tax Affairs confirmed in September 2025 that adaptation work toward the 1 July 2030 EU ViDA cross-border deadline has begun. Detailed technical guidance has not yet been published; the Portuguese position is to leverage the existing SAF-T (PT) + ATCUD infrastructure rather than build a parallel clearance platform.
Why this matters in 2026
The 2026 State Budget deferrals do not change the architecture, they extend the runway. Businesses that interpret the QES delay as “Portugal is slowing down” are reading it wrong. Portugal is completing the B2G mandate in 2026 (SMEs and micro now in scope), locking in the QES layer for 1 January 2027, and activating SAF-T Accounting in 2028. The 2026 window is the last operational year in which a business can run on the legacy “PDF + certified software” stack. Every business that issues PDF invoices in Portugal needs a QES integration plan in 2026, not 2027.
E-Invoicing in Portugal Deadlines and Compliance Roadmap
Portugal’s timeline is denser than most European jurisdictions because the country has been building this stack in layers since 2008. The most operationally important dates in the current window are below.
| Date | Milestone | Status |
|---|---|---|
| 18 April 2019 | Public administrations must receive structured e-invoices (Directive 2014/55/EU) | Done |
| 1 January 2021 | Large enterprises must issue CIUS-PT e-invoices to public bodies | Done |
| 1 January 2022 | QR code mandatory on every invoice issued by certified software | Done |
| 1 January 2023 | ATCUD mandatory on every invoice; non-residents brought under certified-software regime | Done |
| 8 October 2025 | 2026 State Budget Draft Law No. 37/XVII/1 presented to Parliament | Done |
| 27 November 2025 | 2026 State Budget approved; QES deferred to 2027, SAF-T Accounting deferred to 2028 | Done |
| 1 January 2026 | B2G mandate extended to SMEs and micro-enterprises | Done |
| Monthly, 5th of following month | SAF-T Billing submission to AT | Recurring |
| 31 December 2026 | End of transitional regime: last day PDF invoices accepted without QES | Planned |
| 1 January 2027 | QES mandatory on every PDF invoice in B2B and B2C | Planned |
| 2028 (July) | First mandatory SAF-T Accounting submission (FY 2027) | Planned |
| 1 July 2030 | ViDA cross-border B2B e-invoicing and digital reporting deadline | Firm (EU) |
For broader European context, see E-Invoicing in Europe, and for the EU policy framework, see VAT in the Digital Age (ViDA).
Is e-Invoicing Mandatory in Portugal?
The honest answer is: the format is mostly optional, but the process is universal. As of May 2026:
- B2G: Mandatory structured CIUS-PT for all suppliers, regardless of size, since 1 January 2026.
- B2B (format): Voluntary. PDF, EDI, paper, or structured XML are all valid as the delivery channel.
- B2B (process): Mandatory. Every invoice must be issued by AT-certified software, carry ATCUD and QR code, and be reported via SAF-T Billing monthly.
- B2C: Same process obligations as B2B. No structured-format mandate. QR code allows consumer participation through the e-Fatura portal.
- PDF invoices (B2B/B2C): Valid until 31 December 2026 without QES; QES mandatory from 1 January 2027.
- Cross-border B2B (intra-Community): Voluntary today; mandatory under ViDA from 1 July 2030.
This should be described carefully. The frequent claim that “Portugal does not mandate e-invoicing” is true in a narrow sense, there is no structured-format obligation for ordinary B2B transactions today, but it dangerously understates the compliance burden. The certified-software requirement, the ATCUD and QR code obligations, and the monthly SAF-T Billing submission are all already in force and apply to every invoice issued in Portugal. The misconception that Portugal is a “low-burden” e-invoicing jurisdiction has produced more compliance failures than almost any other myth in European tax technology.
Portugal E-Invoicing Requirements
Software certification (Modelo 24)
Every invoicing program used in Portugal, by residents and non-residents alike, must be certified by AT. The certification process is governed by Portaria 363/2010 (as amended) and operates through the Modelo 24 declaration submitted via the Portal das Finanças. The software producer (empresa produtora) submits the declaration; AT evaluates the software against technical requirements (RSA cryptographic signing, hash chain integrity, SAF-T export capability, data immutability, ATCUD generation, QR code generation) and, upon approval, issues a certification number that must appear on every invoice produced by that software, in the form “Processado por programa certificado n.º XXXX/AT”. The process typically takes around 30 days.
A critical operational distinction: certification is per invoicing program, not per producer. A software vendor with multiple distinct invoicing products must certify each one separately. Equally critical is the multi-empresa rule: any software that issues invoices on behalf of multiple unrelated taxpayers, i.e., outside the same economic group as the producer, must be certified. The narrow exemption for internally produced software applies only when the software is used within the producer’s own economic group, with copyright retained by the group. SaaS billing systems, multi-tenant invoicing platforms, and any model where a software provider issues invoices on behalf of customers fall squarely under the multi-empresa requirement.
ATCUD and QR code
Every invoice issued by certified software since 1 January 2023 must display an ATCUD (Código Único do Documento) in the format “ValidationCode-DocumentNumber“. The validation code is obtained from AT for each document series before first use through the series communication webservice (or manual registration in the Portal das Finanças). The ATCUD is therefore not a property of the invoice itself but of the series the invoice belongs to, every series the business uses (FT for invoices, FS for simplified invoices, ND for debit notes, NC for credit notes, etc.) must be registered separately and receive its own validation code.
The QR code, mandatory since 1 January 2022 under Portaria 195/2020, encodes the invoice’s key data fields, taxpayer NIF, document type, ATCUD, date, taxable base, VAT amount, totals, hash. Consumers scan it into the e-Fatura portal to claim VAT deductions; AT uses it for audit. The QR code is mandatory on both paper invoices and PDF/electronic invoices; it may be omitted only for taxpayers using EDI.
SAF-T (PT) reporting
SAF-T (PT) is the structured reporting layer that gives AT visibility into the population of invoices being issued. It comes in two categories:
- SAF-T Billing. Monthly submission by the 5th day of the following month. Submitted through e-Fatura webservice, command-line tools, file upload to Portal das Finanças, or, for low-volume issuers, direct entry. Contains: Header, Customer, TaxTable, Payments, Supplier, Product, SalesInvoices, MovementOfGoods, WorkingDocuments. Applies to all taxpayers subject to Portuguese invoicing rules carrying out VAT-taxable transactions.
- SAF-T Accounting. Annual submission, mandatory for corporate taxpayers and resident entities filing IES/DA with Annex A (commercial, industrial, or agricultural activities) and non-resident entities with a permanent establishment in Portugal. First mandatory submission is now July 2028 (for FY 2027), per the 2026 State Budget. Must be submitted and validated by AT before the IES/DA can be filed; AT validation should occur within 10 days of submission. Contains: Header, Customer, TaxTable, Payments, GeneralLedgerAccounts, Supplier, GeneralLedgerEntries, FixedAssets, Inventory.
Both files are XML based on the official AT XSD structure. The recommended maximum file size for SAF-T Billing is currently 40 MB; the accounting file must be unique per period.
B2G specifics (CIUS-PT)
For B2G transactions, the structured-format mandate adds requirements on top of the universal stack:
- Format: CIUS-PT, the Portuguese Core Invoice Usage Specification under EN 16931, implemented as UBL 2.1 or CEFACT XML.
- Transmission: FE-AP platform operated by eSPap (web service or AS2 integration); FE-AP Microportal for suppliers issuing fewer than 250 invoices per year to public bodies; third-party certified portals; Peppol via accredited Access Points.
- Peppol: eSPap is the Portuguese Peppol Authority. Peppol BIS Billing 3.0 is an accepted format for B2G delivery alongside CIUS-PT.
- Archiving: 10 years for all invoices and supporting documents, in line with the general Portuguese invoicing rule.
Current rules vs. expected 2027+ rules: a side-by-side view
The table below summarises how the operational requirements are evolving across the 2026–2028 window.
| Compliance area | Current rules (2026) | Expected 2027–2028 rules |
|---|---|---|
| Software certification | Mandatory; Modelo 24 via AT | Mandatory (continuity) |
| ATCUD | Mandatory on every invoice | Mandatory (continuity) |
| QR code | Mandatory on every invoice | Mandatory (continuity) |
| Hash chain (RSA) | Mandatory on every invoice | Mandatory (continuity) |
| SAF-T Billing | Monthly by 5th | Monthly by 5th (continuity) |
| SAF-T Accounting | Not yet mandatory | Mandatory from 2028 (FY 2027) |
| PDF as valid e-invoice | Valid through 31 Dec 2026 | No longer auto-valid; QES required from 1 Jan 2027 |
| QES on PDF | Optional | Mandatory from 1 Jan 2027 |
| B2G CIUS-PT issuance | Mandatory for all sizes | Mandatory (continuity) |
| Archiving | 10 years | 10 years (continuity) |
When Will E-invoices in Portugal Become Mandatory?
Portugal’s answer to this question is split across multiple regimes because Portugal does not have, and does not currently plan, a single B2B e-invoicing “go-live” date. Instead:
For B2G structured invoicing, the answer is already. Large enterprises since 1 January 2021; SMEs and micro-enterprises since 1 January 2026. Every supplier to Portuguese public administration is now in scope.
For PDF invoices in B2B and B2C, the answer is 1 January 2027, when the QES requirement kicks in. From that date, a PDF without a QES is no longer a valid electronic invoice. Businesses have three paths to comply: apply a QES to every PDF; switch to structured CIUS-PT XML (which does not require a separate QES because the format provides equivalent authenticity guarantees); or use a certified EDI system.
For SAF-T Accounting, the answer is July 2028 for FY 2027 transactions, per the latest 2026 State Budget deferral.
For cross-border intra-Community B2B, the answer is fixed by EU law: 1 July 2030 under ViDA (Council Directive (EU) 2025/516, published 25 March 2025). Portugal has confirmed that ViDA adaptation work has begun and that the existing SAF-T (PT) + ATCUD infrastructure will be leveraged rather than replaced.
This should be described carefully. Portugal has historically deferred deadlines multiple times, the QES requirement has slipped from 2024 to 2025 to 2026 to 2027, and the SAF-T Accounting first submission has moved from 2024 to 2027 to 2028. The 2027 QES date is currently firm in law (under the 2026 State Budget) but Portugal’s pattern of incremental deferral is well established. Businesses should plan around the legal deadline while remaining alert to further postponement.
Who is Obliged to Use e-Invoicing in Portugal?
The universal stack (everyone)
The certified software, ATCUD, QR code, and SAF-T Billing obligations apply to:
- All Portuguese-resident VAT taxpayers subject to Portuguese invoicing rules.
- All non-resident businesses VAT-registered in Portugal (since 1 January 2023, with no foreign-company exemption).
- All corporate taxpayers and business entities covered by Annex A of IES/DA, resident entities mainly carrying out commercial, industrial, or agricultural activities, plus non-resident entities with a permanent establishment in Portugal, are additionally subject to SAF-T Accounting from FY 2027.
B2G structured-format mandate
From 1 January 2026, all suppliers to Portuguese public administration, regardless of size or sector, must issue structured CIUS-PT e-invoices. The supplier population now includes large enterprises (since 2021), small and medium-sized enterprises, and micro-enterprises. The receiving public bodies have been obligated to receive structured e-invoices since 18 April 2019.
The 2027 QES requirement
From 1 January 2027, every business issuing PDF invoices in B2B or B2C transactions must apply a Qualified Electronic Signature to each PDF, or move to structured CIUS-PT format or a certified EDI system. There is no size-based exemption from this requirement.
Software providers (multi-empresa)
Any software provider that issues invoices on behalf of multiple unrelated Portuguese taxpayers, i.e., outside the same economic group as the provider, must certify its billing software with AT under Modelo 24. The narrow exemption for internally produced software within the same economic group does not apply to SaaS billing platforms, multi-tenant ERP modules, or service providers issuing invoices for unrelated customers.
This is the operational distinction that drives every Portugal go-live decision for software vendors. RTC operates a certified billing solution under the AT framework, supporting both the multi-empresa model (issuing invoices on behalf of multiple customers using RTC’s certification) and the transmission-only model (where the customer’s ERP holds the certification and RTC handles SAF-T extraction and submission).
How to Generate e-Invoices in Portugal?
The certified-software prerequisite
Every Portugal invoice generation workflow begins with the same question:
Which certified software is producing the invoice, and whose certification number will appear on it?
Three operational models exist:
- In-house certified ERP. The customer’s own ERP, SAP, Oracle, Primavera, Sage, etc., is itself AT-certified. The certification number on every invoice belongs to that ERP. A separate service provider may be engaged only for SAF-T extraction and transmission; no additional software certification is needed because the ERP is the invoice-producing system.
- Third-party certified SaaS or service provider (multi-empresa). The provider’s own software is AT-certified under Modelo 24 and issues invoices on behalf of customers. The certification number on every invoice belongs to the provider. Each customer creates a sub-user (sub-utilizador) in their own Portal das Finanças with WSE permission (series communication via webservice) and WFA permission (invoice data communication via webservice), and provides those credentials to the provider. RTC operates in this model when generating invoices for customers without their own certified ERP.
- Direct entry through Portal das Finanças. For very low volumes, primarily micro-businesses, invoices can be issued directly through the e-Fatura portal. AT effectively acts as the certified software in this model.
FAQs About E-Invoicing in Portugal
What is the standard format for E-Invoices in Portugal?
For B2G, the standard is CIUS-PT, the Portuguese Core Invoice Usage Specification under EN 16931, implemented as UBL 2.1 or CEFACT XML. For B2B and B2C, there is no mandatory structured format, PDF, EDI, paper, or XML are all valid delivery channels. All invoices, regardless of channel, must be issued by AT-certified software and carry ATCUD plus QR code. From 1 January 2027, PDF invoices additionally require a Qualified Electronic Signature.
How does e-invoicing benefit businesses in Portugal?
The certified-software regime, while burdensome to implement, produces substantial downstream benefits: SAF-T reporting automation, real-time visibility into invoice data, integrated VAT return preparation, faster reconciliation through ATCUD and hash chain integrity, and consumer participation through the QR code / e-Fatura mechanism (which drives VAT deduction claims and improves customer experience for B2C businesses). International benchmarks for structured-invoicing savings (€5–€8 per invoice processed) apply to the Portuguese context to the extent that the move is from paper to certified-software-issued PDFs or XML.
Can small businesses benefit from e-invoicing in Portugal?
Yes, but the obligations apply equally to small businesses. Micro-enterprises can issue invoices directly through the e-Fatura portal without contracting certified software, which significantly reduces implementation cost. From 1 January 2026, small, medium, and micro-enterprises supplying public administration must issue CIUS-PT structured invoices, a meaningful step up from B2B-only operations. The FE-AP Microportal supports manual upload for suppliers issuing fewer than 250 invoices per year to public bodies.
Are there any exemptions to the e-invoicing requirements in Portugal?
The most consequential exemption is the internally produced software exemption from the certification requirement, applicable only when invoicing software is produced and used within the same economic group, with the group holding the copyright. This exemption does not apply to multi-empresa scenarios (software issuing invoices on behalf of unrelated taxpayers), to SaaS billing platforms, or to service providers. Small B2C cash-register exemptions exist for very low-volume operators. There is no foreign-company exemption, non-resident VAT-registered businesses have been subject to certified software, ATCUD, and QR code requirements since 1 January 2023.
How can businesses in Portugal prepare for the e-invoicing transition?
Confirm which software is producing invoices and whose AT certification number appears on them. Audit the certified-software stack against current technical requirements (RSA hash chain, ATCUD generation, QR code per AT specification, SAF-T export). Register all document series with AT and obtain validation codes before first use. Plan QES integration for January 2027 if PDF invoicing will continue. For B2G suppliers, complete CIUS-PT integration if not already done. For corporate taxpayers, plan SAF-T Accounting compliance for July 2028 (FY 2027). Track 2026 State Budget enforcement guidance as AT publishes it.
What software solutions are available for e-invoicing in Portugal?
Three categories: (1) AT-certified Portuguese ERPs (Primavera, Sage Portugal, PHC, etc.) that natively produce certified invoices; (2) major international ERPs with AT-certified Portuguese localisations (SAP, Oracle, Microsoft Dynamics); (3) certified third-party billing and reporting providers operating under the multi-empresa model. RTC operates a certified billing solution under the AT framework, supporting both invoice generation and SAF-T extraction/submission. For B2G transmission, the eSPap-operated FE-AP platform is the central public-administration channel; Peppol Access Points provide an alternative B2G delivery route.
Are there penalties for non-compliance with e-invoicing regulations in Portugal?
Portugal’s penalty regime under the General Tax Infraction Regime (RGIT) is among the more aggressive in Europe. Use of non-certified software carries fines of €3,000–€18,750 per infraction. Improper invoicing (missing ATCUD, missing QR code, invalid hash chain, missing certified-software number) carries fines of €150–€3,750. Late or incomplete SAF-T Billing submission carries graduated fines. Penalties are doubled for fraudulent or intentional infractions.
Penalties can apply per customer or per transaction depending on the infraction type, which means the exposure for a multi-empresa software provider operating without certification can scale rapidly. Beyond formal penalties, B2G suppliers face procurement disqualification for non-compliance with CIUS-PT issuance, and B2B counterparties increasingly impose certified-software and ATCUD verification as a contractual condition.