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Portugal has taken major steps toward digitalizing its tax system. Since 2022, e-invoicing has been mandatory for business-to-government (B2G) transactions, initially for large companies and later extended to medium, small, and micro-enterprises under Decree 28/2019. The mandate is aligned with EU Directive 2014/55/EU and Decree 123/2018, requiring public authorities to process electronic invoices. eSPAP coordinates Portugal’s B2G e-invoicing platform. Currently, B2B e-invoicing is not mandatory in Portugal, though trends across Europe indicate a likely future expansion. This blog explains timelines, requirements, data transmission, and SAP compliance solutions for ECC and S/4HANA systems supporting full legal compliance nationwide.
Timeline e-invoicing implementation in Portugal
The Portugal e-invoicing timeline outlines the gradual rollout of mandatory electronic invoicing requirements, highlighting key regulatory milestones from 2019 through 2026. Understanding this timeline is essential for ensuring ongoing compliance with Portugal’s evolving digital tax regulations.
The first major milestone in Portugal’s e-invoicing implementation timeline dates back to 8 April 2019. From that point on, in accordance with EU Directive 2014/55/EU, B2G e-invoicing has been mandatory in Portugal. Consequently, Portuguese public authorities must be able to receive and process electronic invoices.
In 2021, the obligation expanded to large companies, which were required to issue electronic invoices exclusively when invoicing public entities.
In 2022, the Portuguese tax authorities introduced a further milestone, requiring a mandatory QR code on all paper & pdf invoices generated by a certified software.
The timeline progressed further in 2023 in which 3 reforms for non-resident taxpayers were introduced. This includes that foreign businesses VAT registered in Portugal from that point on had to comply with requirements that were already in place for residents:
- Paper or PDF invoices must include a QR Code
- Invoices must be produced by certified invoicing software that can allocate a unique ATCUD code
- Monthly invoice reporting via SAF-T Billing file
Looking ahead, in 2025, the B2G e-invoicing deadline for small and medium-sized enterprises (SMEs) has been postponed to 1 January 2026, providing additional preparation time for affected businesses.
Additionally, there is a new 1-year delay to QES. This means that, until 31 December 2026, Portuguese businesses may continue to issue PDF invoices as electronic invoices. From 1 January 2027 onward, electronic invoices will be required to include a Qualified Electronic Signature (QES) issued exclusively by certified third-party providers. At the same time, annual SAF-T Accounting has also been delayed a year until 2027 (for 2026 transactions).
Who must comply with the e-invoicing requirements?
To complement the Portugal e-invoicing timeline, the section below clarifies who is subject to the e-invoicing requirements.
B2G
E-invoicing is mandatory in Portugal for business-to-government (B2G) transactions and was introduced in phases. Initially, the obligation applied only to large companies, which were required to issue electronic invoices when supplying public sector entities.
Medium-sized, small, and micro-enterprises were also required to comply with B2G e-invoicing, ensuring that suppliers of all sizes use standardized electronic invoicing when dealing with public authorities.
Company size classifications relevant to these rules are as follows:
- Large enterprises: More than 250 employees, annual turnover above EUR 50 million, and/or balance sheet total exceeding EUR 43 million
- Medium-sized enterprises: Fewer than 250 employees, annual turnover up to EUR 50 million, and balance sheet total up to EUR 43 million
- Micro-enterprises: Fewer than 10 employees, with annual turnover or balance sheet total not exceeding EUR 2 million
B2B
Regarding business-to-business (B2B) transactions, there is at present no mandatory e-invoicing requirement. This means businesses can choose in which format they issue the invoice, paper or PDF. To ensure effective VAT control and auditability, there are certain mechanisms in place:
- QR code which must appear on invoices and be generated through AT-certified software
- ATCUD is a unique ID number on an invoice
- SAF-T reporting for invoicing (from 2027, covering 2026 fiscal year)
From 1 January 2026, PDF invoices used in B2B transactions will also be required to include a Qualified Electronic Signature (QES), ensuring a higher level of authenticity and legal certainty. More specifically, the QES replaces the exchange paper documents blue ink signed.
B2C
There is currently no business-to-consumer (B2C) mandate.
The eSPAP platform
What is the eSPAP platform?
eSPap (Entidade de Serviços Partilhados da Administração Pública) is Portugal’s official platform for Business-to-Government (B2G) electronic invoicing, managed by the Shared Services of Public Administration. It allows suppliers to send structured electronic invoices directly to Portuguese public authorities in compliance with national regulations and EU Directive 2014/55/EU.
Who can use the eSPAP platform?
- Public contracting authorities (public institutions & government administrations)
- The issuer of electronic accounts
- Information intermediaries (e-invoice providers for public tenders)
Data transmission with eSPAP B2G e-invoicing Portugal
First of all, in Portugal, two invoice formats are legally accepted by eSPAP:
- UBL 2.1 “CIUS-PT”
- CEFACT “CIUS-PT”
Important to know here is that from 1 January 2022 onwards, it is mandated to provide the e-invoice with a QR barcode and a unique document code.
Last but not least, in Portugal both issuer and recipient must archive all e-invoices for 10 years.
SAP Document Compliance solution for making your SAP system compliant with the B2G e-invoicing requirement in Portugal
- You create the source document (for example, invoice) using an SAP application. Once you post the source document, the system creates an instance of the eDocument in the database.
- You submit the eDocument by running the eDocument Cockpit (EDOC_COCKPIT transaction).
- The system retrieves the eDocument from the database and calls the interface connector to deploy the eDocument Interface connector (EDOC_INTERFACE_CONNECTOR) Business Add-In (BAdI).
- ThisBAdI calls the interface type that enables the system to connect to SAP Application Interface Framework.
- SAP Application Interface Framework triggers the mapping of transactional data into the required XML format and saves the XML files.
- The system calls SAP Cloud Platform Integration via an ABAP Proxy and establishes communication with the service provider’s systems.
- If the call is successful, the outgoing XML file is saved. After successfully receiving the response, the response XML file is saved.
- SAP Cloud Platform Integration processes the XML file to comply with the official communication requirements and triggers the corresponding web services for sending the XML file over to the service provider.
- The service provider validates and forwards the XML file to the corresponding receiver. Once the receiver returns the updated status, the service provider forwards the status to the sender.
- SAP Cloud Platform Integration receives the status from the service provider.
- The sender system pulls the incoming status of the eDocument from SAP Cloud Platform Integration.
- The system updates the eDocument in the database with information received from the external systems.
Why you should comply with the e-invoicing requirements
The most important reason for complying with the E-Invoicing requirements is to avoid paying severe penalties. Non-compliance will namely be fined. Therefore, it is crucial to make the necessary SAP adaptions to ensure compliance with the Portuguese e-invoicing regulations.
Additionally, complying with the requirements brings benefits as well. Not only does it save on paper invoices and avoid penalties, but it also makes the process of verifying, approving and paying the invoices faster, improves security (by minimizing fraud with QES and AT-certified applications) and facilitates auditing and tax reporting with SAF-T files.
These SAP adaptions will most likely require some work and investments. However, the SAP Document Compliance solution brings quite some benefits for your business as well. It is a strategic solution that offers the re-use of SAP licenses and basic configuration for compliance with other country-specific legal requirements. Therefore, it ensures your business compliance in the long run.
How PIKON could help you
At PIKON, we have set up a Competence Center for Legal Requirements. Here our consultants investigate legal requirements worldwide and their impact on the SAP system. Our team consists of experts that combine in-depth knowledge as well as the experience gathered through our many SAP Document Compliance and local implementation projects all around the world. Examples of these projects are SDI in Italy, SII in Spain, CFDI and Complemento de Pago in Mexico, RTIR and EKAER in Hungary, XRechnung and ZUGFeRD in Germany, E-Invoicing and E-Archive in Turkey, MyDATA in Greece, Crea y Crece in Spain, KSeF in Poland and many more. We are a strategic partner who offers clients the best suitable solution to ensure that their SAP system and business processes meet different country-specific legal requirements in the long run. Furthermore, we follow up regularly on new and changing legal requirements that are relevant for our clients and inform them when action is needed. That way, clients can concentrate on their daily business, without worrying about not being compliant with necessary regulations.
If you have any questions on the Portuguese E-Invoicing regulations, or if you are interested in a system demo regarding the E-Invoicing flow, do not hesitate to request a web meeting or leave a comment in the comments section below. We are happy to help and will come back to you as soon as possible.
