How to Comply with the SAF-T File Requirement in Portugal
Law No. 45-A/2024 of the Assembly of the Republic establishes new dates for the implementation of the SAF-T accounting file and the qualified electronic signature:
SAF-T accounting file: The obligation to submit this file, initially scheduled for 2026, has been postponed to 2027, applying to the fiscal year corresponding to 2026. However, in the event of tax inspections, it is still mandatory to provide this file to the Tax Authority (AT). It is therefore recommended to prepare in advance and implement a system capable of generating the file on-demand to ensure regulatory compliance.
Qualified electronic signature: PDF invoices will remain valid without an electronic signature until December 31, 2025. From January 1, 2026, it will be mandatory to incorporate a qualified electronic signature.
The Standard Audit File for Tax (SAF-T file) is an internationally used electronic file for transmitting tax and accounting data. In Portugal, implementing SAF-T is crucial for improving tax control, promoting transparency, and streamlining compliance with tax requirements.
What is SAF-T?
SAF-T (Standard Audit File for Tax) is an XML-based electronic file designed to facilitate the exchange of tax and accounting information between companies and tax authorities. Its primary objective is to standardize tax data, enabling a more efficient and accurate review of transactions and, therefore, ensuring transparency in accounting processes. Standardizing information enables tax authorities to more effectively monitor and audit business activities, supporting efforts to combat tax fraud.
The file compiles records of invoicing, accounting, and other financial transactions in a format designed for easy analysis by tax authorities or external auditors. Its standardized yet adaptable structure allows governments to integrate it seamlessly into their tax filing systems for audits or tax return submissions.
Legal Framework for SAF-T in Portugal
In Portugal, SAF-T is governed by a series of mandates requiring businesses to submit tax and accounting data digitally. The Código do Imposto sobre o Valor Acrescentado (CIVA) mandates the SAF-T file, while Portaria No. 321-A/2007 specifies technical requirements, including the XML structure to ensure data standardization.
Portaria No. 31/2019 further details the requirements for submitting the SAF-T accounting file to the Autoridade Tributária e Aduaneira (AT), and Decreto-Lei No. 198/2012 outlines the obligations for invoicing and transportation document reporting in SAF-T format. These regulations establish the legal framework requiring companies operating in Portugal to create and submit the SAF-T file.
How SAF-T Works in Portugal
SAF-T is mandatory for businesses with a permanent establishment or effective management within the country. All VAT-registered entities, regardless of size, are required to digitally submit their tax and accounting data.
The Portuguese tax authority, Autoridade Tributária e Aduaneira (AT), recognizes three main types of SAF-T files, each serving distinct purposes:
- SAF-T Billing: This file captures all invoicing and sales data, including VAT declarations, and must be submitted by the 5th of each month.
- SAF-T Accounting: This file details a company's accounting records, such as items, clients, suppliers, and VAT regimes. It’s used for submitting monthly or annual accounting information to the AT.
- SAF-T Transportation Document: This file includes information on transportation-related documents and must be submitted before any goods movement begins, enabling authorities to monitor the flow of products within Portugal.
The SAF-T submission process involves the automatic generation of XML files from a company's management systems, following established standards. Files must be submitted to the AT based on the accounting period—either monthly or annually—in accordance with the fiscal deadlines specified in Portuguese legislation.
Technical Requirements for SAF-T File Generation
The SAF-T file must be generated in an XML format, adhering to the technical specifications set out in Portaria No. 321-A/2007, which ensures data is standardized and readable. To comply with these requirements, companies must use software certified by the Autoridade Tributária e Aduaneira (AT) that can generate files according to the specified standards.
Automation is key to the SAF-T generation and submission process. Businesses must ensure their management systems are integrated with software that automates the capture of tax and accounting data, enabling timely compliance with current regulations.
EDICOM, a solution to comply with SAF-T Portugal
EDICOM's solution for managing SAF-T files in Portugal is fully audited and certified by the AT, complying with the technical standards outlined in Portaria No. 363/2010 and Portaria No. 340/2013. These regulations define certification criteria for billing software, ensuring EDICOM’s solution meets strict security and compliance standards for the automated generation, signing, and submission of SAF-T files.
In addition to regulatory compliance, EDICOM’s solution allows SAF-T file generation to be directly integrated with company management systems, automating both file generation and submission to the AT, reducing errors, and facilitating timely compliance. It also offers secure document storage, guaranteeing the long-term integrity and accessibility of SAF-T files.
