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Portugal: B2G E-Invoicing Requirements with SAP (ECC & S/4HANA)

At the moment, e-invoicing in Portugal is only mandatory in the area of business-to-government (B2G) transactions. This B2G e-invoicing requirement in Portugal is based on existing models of B2G e-invoicing which are implemented in other European countries. The reason behind the adoption in Portugal follows directly from the European Directive 2014/55/EU and Decree 123/2018, which states that the Portuguese public sector should be able to process electronic invoices by 2020. The coordinating organization for B2G e-invoicing in Portugal is Entidade de Serviços Partilhados da Administração Pública (eSPAP). 

Concerning the business-to-business environment in Portugal, there is no existing requirement mandating B2B e-invoicing in Portugal as we can see in other European countries such as Italy, Hungary, … Therefore, the Portuguese eSPAP platform is not developed for processing B2B invoices, as it is solely focused on B2G e-invoicing.  However, developments and trends which I can see in other countries (also first starting with B2G e-invoicing) give strong incentives that mandatory B2B e-invoicing in Portugal is just a matter of time. As soon as official announcements from the Ministry of Economy, Entrepreneurship and Trade regarding B2B e-invoicing in Portugal are published, I will write a new blogpost about the requirement and the corresponding SAP solution.  

This blog post will give you more information about the detailed timeline concerning B2G e-invoicing in Portugal. You will learn more about data transmission and what SAP solution we can offer to make your SAP system (ECC and/or S4HANA) compliant with the Portuguese B2G e-invoicing requirement.

Timeline B2G e-invoicing in Portugal

Timeline of B2G E-invoicing in Portugal

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

Compliance Process
  1. 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.
  2. You submit the eDocument by running the eDocument Cockpit (EDOC_COCKPIT transaction). 
  3. 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).
  4. ThisBAdI calls the interface type that enables the system to connect to SAP Application Interface Framework.
  5. SAP Application Interface Framework triggers the mapping of transactional data into the required XML format and saves the XML files.
  6. The system calls SAP Cloud Platform Integration via an ABAP Proxy and establishes communication with the service provider’s systems.
  7. If the call is successful, the outgoing XML file is saved. After successfully receiving the response, the response XML file is saved.
  8. 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.
  9. 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.
  10. SAP Cloud Platform Integration receives the status from the service provider.
  11. The sender system pulls the incoming status of the eDocument from SAP Cloud Platform Integration.
  12. 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. 

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, DIAN in Colombia, MyDATA in Greece 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. 

Contact us!

Do you have any questions about the E-Invoicing regulations of Portugal? 
Feel free to contact us for a personal web meeting.

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About the author
Sifeddine Salhane
Sifeddine Salhane
Sifeddine Salhane was an SAP ERP Consultant at PIKON Benelux in Genk, Belgium with the focus on the integration between the SAP SD and the SAP FI modules. Within our international PIKON group, he was part of PIKON’s Competence Center for Legal Requirements.

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