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In 2014, the Portuguese government introduced regulations to govern the exchange of electronic invoices between private businesses. As a result, the use of digital signatures on electronic invoices became mandatory.
Building on this framework, the Portuguese tax authorities announced in 2020 that, from January 1, 2022, companies must communicate the number range series identifiers used for invoices, deliveries, and other fiscally relevant documents to the tax authorities. For each series submitted, the authorities issue an AT validation code (ATCUD).
The ATCUD has been mandatory since January 1, 2023. It must be printed on the relevant documents together with the QR code, included in e-invoicing processes, and reported in the SAF-T (PT) file.
The ATCUD code
The ATCUD code will uniquely identify electronic invoices and will confirm their validity. To create an ATCUD code, businesses must initially register every series of invoices with the Portuguese tax authority (AT) and receive an associated validation code for that particular series. The tax authority then supplies the validation code, which must be used to generate the ATCUD for each invoice issued in that series.
POS and invoicing systems are required to automatically produce the ATCUD for every invoice and related document, making sure it is prominently displayed on both printed and digital invoices, usually in the header or a specified section. Additionally, these systems must ensure strict sequential numbering of invoices, preventing any gaps or retroactive dating, while maintaining a comprehensive audit trail that records the ATCUD along with the related invoice information. Furthermore, when a business employs multiple invoice series such as for POS transactions, online sales, or backup systems, each series must be handled individually and possess its own validation 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.
A QR code is a two-dimensional barcode that contains all the necessary data about the specific electronic invoice on which it is printed. This includes key information such as buyer and seller details, VAT numbers, invoice totals, and other data specified by the Portuguese Tax Authority. These codes serve as a validation tool for each invoice, allowing customers to scan and upload invoices directly to the eFatura Portal, which eliminates manual data entry and streamlines processing.
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.
Since 2022, companies have been required to use SAF-T (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.
SAF-T (PT) mandates that monthly XML submissions be reconciled with the VAT return, along with an annual report summary. These files must be created using software that is approved by the AT and submitted by the 20th of the month after the reporting period.
At present, there are three main SAF-T (PT) ledgers:
- Accounting: Captures data necessary for creating the electronic accounting file, which includes items, clients, suppliers, VAT categories, accounting transactions, and the accounting framework. This information is utilized for the annual IES reporting statement.
- Billing Reporting: Electronic VAT return submissions are required monthly by the 5th of each month (previously by the 12th). Files need to be generated in order and must undergo an encryption process, employing the electronic signature from the prior invoice as a control mechanism.
- Transport Documents: Information is sent in real-time to AT, with a code that is automatically generated and integrated into transport documents to facilitate the tracking of goods movement.
SAF-T Accounting
Portugal intends to implement mandatory SAF-T Accounting in 2027, which will include reporting for the financial year 2026. This initiative will broaden reporting requirements beyond just invoices to encompass detailed accounting data such as: the Chart of accounts, accounting journals and transactions, VAT categories, master data for suppliers and customers, and the article (product) catalogue.
QES
A Qualified Electronic Signature (QES) is a legally recognised digital signature that offers a high level of security and authenticity, created according to Regulation (EU) No. 910/2014 (eIDAS) by a qualified trust service provider. These providers are certified and possess the necessary technology to deliver secure electronic identification services, including electronic signatures. Beginning on January 1, 2027, PDF invoices are required to incorporate a QES to meet invoicing standards, so businesses should implement these signatures to ensure compliance with the law and improve the security of their digital transactions.
The SAP solution
The SAP solution is a centralized framework that manages the ATCUD codes and document series. It offers 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.
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 & Reporting 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.
Contact us!
If you have any questions on these Portuguese regulations or if you would like more information about the SAP solution, 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.
