top of page

Portugal and e-Invoice

Updated: Feb 7


In this article, we will try to assess SAF-T processes in Portugal and the public administrations involved in these processes.

As in other EU countries, EU Directive 2014/55 regulated the implementation and receipt of e-invoicing for public procurement in Portugal. Managing and coordinating the e-invoicing process are carried out by ESPAP (Department for Public Administration Services). The model chosen by Portugal allows local organizations to select their e-invoicing solution. It is also a decentralized model that uses the solution provided by ESPAP.

What is SAF-T?

The Portuguese Ministry of Finance has created an additional requirement. Therefore, for every invoice arranged an electronic document is issued. And to be shown to the tax office before sending to customers is presented. The SAF-T is a specification for a computer-readable file that transfers accounting data from the original accounting system into a predefined format derived from XML and makes it available for tax authorities for external auditing. Regardless of the program used with SAF-T, transport documents and receipts can be issued in a common and readable format without affecting the internal structure or functionality of the program database.

SAF-T Portugal Edition (PT)

Since 2013 the SAF-T Portugal Edition (PT) file was also used as the basis for the regular submission of invoicing and logistics data to the tax authorities by taxpayers (via the e-invoicing website). The SAF-T (PT) file intends to facilitate gathering relevant tax data in electronic form by tax inspectors to aid taxpayers’ tax returns and analyze accounting records. In this regard, the SAF-T (PT) document requires an XML structure. There is no specific format for invoice status. Interested parties can agree to use existing standards (EDIFACT, X12, XML). SAF-T must be manufactured on a computer system approved by the Portuguese Tax and Customs Administration (Autoridade Tributária e Aduaneira – AT). It must be declared through public network services. The invoice to be sent to the customer must contain the SAF-T file and a unique code received with the response from AT. This code includes the signature of the previous invoice so that invoices are guaranteed one after the other.

Transmission of financial and logistical information to AT in the Portuguese version of SAF-T

In 2008, a requirement to create a Standard Audit File for Tax Purposes (SAF-T (PT)) was introduced for headquartered organizations to conduct a more efficient tax audit and reduce time using technological tools. In 2011, the Portuguese Tax and Customs Administration (AT) started a certification program for invoicing and logistics software. In 2013, the monthly notification to the AT began about invoices, receipts, and transport documents. In 2014, the “Invoice Lottery” application started increasing the invoice demand of end-users. In 2015, the monthly notification of the working documents and the inventory notification to AT began at the end of the year.

It is possible to summarize how SAF-T (PT) works: sales invoices (documentos comerciais a clientes), transport documents (documentos de transporte), and customer payments are recorded directly in the accounting system. A standard SAF-T (PT) file in XML format is created from the data processed in the accounting system. This file is the source for the tax return. Sales transmit to AT via the finance portal (Portal das Finanças). Transport documents (transport documents: Guia de Remessa, Guia de Transporte, invoice) are sent to AT after a standard SAF-T (PT) file has been created in XML format.

In this article, we will examine the concepts of billing and shipping documents in Portuguese legislation.

Invoice and transport document in Portuguese legislation

In Portuguese legislation, the definition of the transport document is given in the regulation “Regime dos Bens em Circulação“. Accordingly, “transport document” (documentos de transporte) means invoice, waybill/receipt (Guia de remessa), return document, transport document/waybill (Guia de transporte), or equivalent documents.

It is contained in Article 36 (5) of the Sales Tax Act (CIVA-Código do Imposto sobre Valor Agregado).

  1. Name and registered office or the registered office of the goods or service provider as well as the taxable recipient, company, and tax identification numbers of the respective persons

  2. Name of the goods or services transferred

  3. After-tax price and other factors included in the tax amount

  4. Tax rate and tax amount payable

  5. The date the goods delivered to the buyer or payment made before the service transaction carried out

ESPAP and e-Invoicing

ESPAP coordinates the implementation of the electronic invoice (Invoice Eletrónica na Administração Pública “FE-AP”) in the public administration. ESPAP develops tools to support the implementation of electronic invoicing and to determine the technical and functional requirements. In this context, the FE-AP portal can be used by public institutions and enables direct integration into the Financial Resource Management solution (GeRFiP-Gestão de Recursos Financeiros) or any accounting or document management system via the Internet.

The aim was to support public institutions by receiving and checking B2G invoices. Another solution tool, B2AP (Business to AP Portal), is intended to support AP (Public Administration) suppliers as co-contractors in monitoring the delivery and progress of electronic invoices sent to the FE-AP portal.

According to the provisions of Decree No. 14-A / 2020, public administration suppliers must send their invoices in UBL 2.1-CIUS PT format according to the specified format. In this context;

  • Large companies through January 1, 2021

  • Small and medium-sized businesses by July 1, 2021

  • Until January 1, 2022, micro-enterprises and public institutions as contracting authorities cannot receive invoices in a format other than the European standard UBL 2.1-CIUS PT set by the Portuguese government.

Invoicing portal for e-invoice and e-waybill transactions

In Portugal, transactions related to electronic invoices and electronic transport documents carry out through Examples of transport documents to be issued for different phases will be published on the portal. You can use the portal to send SAFT PT files, collect invoices, and access compliance support functions. Using all these functions, you have to register with the Portuguese tax and customs authorities.

Direct stakeholders in the e-invoicing implementation program

Using of electronic invoices in public contracts is gradually being made by the public and joint contractors. Micro, small and medium-sized enterprises are companies that have been defined by Recommendation 2003/361 of the European Commission of May 6, 2003.

  • Large companies (P> 250 people): The use of the electronic invoice is not mandatory until 01/01/2021. After 01/01/2021, e-bills are mandatory.

  • Medium-sized companies (250> P ≥ 50 people) and small companies (50> P ≥ 10 people): The use of the electronic invoice is not mandatory until July 1st, 2021. After July 1st, 2021, e-bills are mandatory.

  • Small businesses (P <10 people) and public institutions: The use of e-bills is not mandatory until January 1st, 2022. After 01/01/2022, e-bills are mandatory.


Portuguese financial management, which, like many EU countries, would like to benefit from the advantages of electronic invoices, has a financial and technical infrastructure. For large taxpayers, processes such as e-invoices and e-transport documents are exchanging quickly and flexibly online. Now is the time to spread this advanced improvement to medium and small businesses.


Recent Posts


Rated 0 out of 5 stars.
No ratings yet

Add a rating
bottom of page