Portugal: Electronic Invoice with the Public Administration

Electronic invoicing in Portugal is mandatory in transactions between suppliers and public administrations. The eSPap, Shared Services Entity of the Public Administration, plays the role of coordinating entity in the implementation of the electronic invoicing system in Portugal.

Legal framework for B2G electronic invoicing in Portugal

Electronic invoicing in Portugal is regulated by Decree Law 111-B/2017, which details Directive 2014/55/EU on the use of electronic invoicing in public procurement, mandatory for all member states. This Decree Law was later amended by Decree 123/2018 to define new features of the model and different implementation phases.

Electronic invoicing system in Portugal

The electronic invoicing system in the public administration of Portugal is based on a decentralized model, allowing public bodies to use the invoice reception platform provided by eSPAP or develop their own platforms for receiving, validating, and processing invoices. Connection can be made through the AS2 protocol or via Web Services.

Public Entities obliged to use the eSPap platform

• Direct Government Administrations
• Public Institutes

Public Entities voluntarily using the eSPap platform

• Presidency of the Republic
• Assembly of the Republic
• Attorney General's Office
• Courts
• Independent administrative entities
• Public Sector Business Entities (Hospitals)
• Universities

Characteristics of electronic invoicing in Portugal

The mandatory documents for issuance in transactions with public administrations are the invoice, credit note, and debit note.

Invoice format: The two formats approved by the public administration can be used: UBL 2.1 "CIUS-PT" and CEFACT "CIUS-PT".

Elements that the structured file must contain:

• Process and invoice identifiers
• Billing period
• Information about the co-contractor
• Information about the public contractor
• Information about the beneficiary entity if different from the above
• Information about the co-contractor's tax representative
• Contract reference
• Delivery conditions
• Payment instructions
• Information about adjustments and charges
• Information about invoice items
• Total invoice amount

Electronic signature and storage: Electronic signature is mandatory, and the archiving of invoices for 10 years is required for both the issuer and the recipient.

Unique Document Code (ATCUD) and Two-Dimensional QR Code

The Portuguese tax authority, Autoridade Tributária e Aduaneira (AT), has mandated the inclusion of the Unique Document Code (ATCUD) and the two-dimensional QR code on invoices and relevant tax documents. These measures aim to streamline invoice communication, improve transaction tracking, and combat the informal economy, fraud, and tax evasion.

The ATCUD code must be included on all invoices, ensuring readability whether they are presented electronically or in print. The QR code requirement applies only to paper invoices or signed PDFs. For multi-page documents, the ATCUD must appear on every page, while the QR code can be placed on either the first or last page.

Requirements for Including ATCUD and QR Codes on Invoices

• Use AT-certified software.
• Obtain the Series Validation Code from the AT.

EDICOM Global Electronic Invoicing Platform

If your company has an electronic invoicing project in Portugal or any other country worldwide, EDICOM can help you with your tax obligations. Our platform allows integrated management of electronic invoicing with Portuguese public administrations, as well as other tax-related telematic procedures such as the SAF-T accounting file declaration.

EDICOM offers its clients a global solution that complies with all technical requirements established in the Portuguese B2G electronic invoicing system or any other country in the world.