Electronic invoicing and e-Reporting 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.

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.

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.

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.

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.

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.

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.

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.

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.

During 2026, large companies supplying Portuguese public administrations must issue structured electronic invoices in accordance with the requirements of the Public Contracts Code. This obligation may also apply to foreign suppliers acting as contractors under Portuguese public procurement contracts.

Microenterprises and SMEs may continue to use alternative invoicing mechanisms until 31 December 2026. If no further extension is approved, they will have to adopt structured B2G electronic invoicing from 1 January 2027.

No. Portugal does not yet impose a general obligation to use structured electronic invoices for transactions between private companies. Businesses may continue to exchange invoices on paper, as PDFs or in other electronic formats, provided they comply with the applicable tax requirements.

Although B2B electronic invoicing is not mandatory, companies must report invoice data to the Portuguese Tax and Customs Authority and, where applicable, comply with the requirements relating to certified software, the ATCUD, the QR code and SAF-T PT.

Yes. Until 31 December 2026, invoices in PDF format are accepted as electronic invoices for all purposes under Portuguese tax legislation.

However, the tax validity of a PDF does not mean that this format automatically satisfies the B2G electronic invoicing requirements. Companies already required to issue structured invoices under public procurement contracts must use the formats and channels specified by the receiving entity.

From 1 January 2027, if no further extension is approved, electronic invoices must guarantee the authenticity of their origin and the integrity of their content through mechanisms accepted under Portuguese law, such as a qualified electronic signature, a qualified electronic seal or an electronic data interchange system.

Whether electronic invoicing is mandatory in Portugal depends on the type of transaction and the size of the company. In the B2G sector, large companies must issue structured electronic invoices when billing public administrations under public procurement contracts. SMEs and microenterprises benefit from a transitional regime until 31 December 2026. There is not yet a general obligation to use structured electronic invoices for B2B and B2C transactions.