In 2014 the Portuguese government decided that the interchange of electronic invoices between private businesses need to be regulated. From this point implementing digital signatures on electronic invoices is mandatory.
In 2020 the Portuguese tax authorities also confirmed that from 1 January 2022 on, companies require to print a QR code in fiscally relevant documents. For example, SD billing invoices, debit and credit memos, and delivery notes. Companies will also be required to obtain a new series validation code and then use it to generate an AT-Validation Code (ATCUD). Implementing this ATCUD regulation will be optional in 2022 and will become mandatory in 2023.
The ATCUD code
The ATCUD code will uniquely identify electronic invoices and will confirm their validity. To generate this specific ATCUD code, companies need to obtain a validation code for their series from the Portuguese tax office. The tax office will then provide the company with the respective validation code which needs to be used to generate the ATCUD code.
The structure of the ATCUD code defined by the Portuguese government is composed out of two parts:
- a validation code, which is a string of a minimum of eight characters assigned by the tax office
- a sequential number of the electronic invoice within a series
The QR code
Next to the ATCUD code, all businesses that operate in Portugal will need to add a QR code to their electronic invoices, including foreign companies VAT registered in Portugal.
This QR code will contain all necessary data about the specific electronic invoice on which it is printed. The Portuguese tax authority has published all the required codes, which reflect the details which have to be in the QR code.
QR code and SAF-T
SAF-T is an electronic file type format based on the XML standard. The aim was to create guidance for the audit file itself and tax compliance. The SAF-T is standardized in terms of format and meaning. There can be some small country-specific elements that differ from country to country. For a more in-depth view of SAF-T, check out this blog post.
SAF-T in Portugal was made mandatory in 2013, which meant that all companies were obliged to send invoices and transport documents in this specific SAF-T format.
In 2022 companies will be required to use SAFT-PT, an electronic accounting document format. The new requirement can be declared on a monthly or yearly basis. It should contain control fields such as VAT regimes, Supplier and Client list, Article catalogue, Chart of accounts and accounting movements.
Some information included in the QR code is also listed in SAF-T. To link the information in the QR code with the SAF-T obligations, you need to create a mapping.
The SAP solution
The SAP solution is a centralized framework that manages the ATCUD codes and document series. They will offer two solutions, a manual and an automatic solution. A new Number Range with the new Series definition has to be created based on the restriction of the Portuguese tax authorities to make sure that these codes are unique.
The manual solution requires that the Number ranges/series need to be entered on the Portuguese tax authority portal manually. The system will then return the updated validation codes.
In the automatic process, the SAP solution communicates the Number ranges/series to the tax authority. Afterwards, it stores the returned validation code automatically. This automated communication is done by using a web service for example, by integrating SAP Cloud Integration (CPI) onto your SAP system.
SAP is currently working on these solutions, expected to be released between February and March 2022.
Why you should comply with these new reporting requirements
The most important reason to comply with the new Portuguese reporting regulations is to avoid paying penalties, as non-compliance will result in a fine. To help you avoid these fines, you can make use of the SAP solutions to ensure compliance with these new regulations.
How PIKON can 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 and the gathered experience, through our many SAP Document Compliance and local implementation projects all around the world. This is how the topic, concerning the new Portuguese regulation of the QR code and ATCUD code, came onto our radar.
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 relevant for our clients and inform them when action is needed. That way, clients can concentrate on their daily business without worrying about non-compliance with necessary regulations.
If you have any questions on these Portuguese regulations or if you would like to receive a heads-up when the SAP solution is ready, 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.