Q: Are PDF invoices accepted as legal electronic invoices in Portugal?

Yes. Under Article 95(3) of Law 73-A/2025 , PDF invoices are legally deemed to be electronic invoices for all tax purposes until 31 December 2026. A proposal in the draft 2027 State Budget would extend this treatment to 31 December 2027, but remains unapproved.

Q: When must smaller businesses comply with B2G e-invoicing?

Under Law 73-A/2025, Article 260(2) , the transition lasts through 31 December 2026. Absent an amendment, covered micro, SME and public-entity suppliers enter the structured B2G obligation on 1 January 2027. Proposed 2027 Budget Article 138(2) would extend that date by one year.

Q: What is the deadline for communicating invoices to the AT?

Under Article 3(2) of Decree-Law 198/2012 , covered document data is due by the fifth day of the following month. Article 3(9) also requires nil-issuance notification, subject to AT's exception for qualifying exclusive electronic green-receipt users.

Q: What are the ATCUD and QR code requirements?

Under Decree-Law 28/2019 and Portaria 195/2020 , applicable documents require ATCUD, with QR-code display on covered visual representations. QR codes became mandatory from 1 January 2022. AT identifies 1 January 2023 as the ATCUD implementation date; its final deferral chain remains to be documented.

Q: What is the small-enterprise VAT exemption threshold in Portugal?

Under Article 53(1) CIVA , qualifying taxpayers with a Portuguese seat or domicile may benefit where preceding-year Portuguese turnover does not exceed €15,000. The €18,750 immediate-exit test applies in the statutory circumstances set out in Article 58; eligible EU businesses have a distinct cross-border regime under Article 53(2).

Question 1

Is electronic invoicing mandatory for domestic B2B transactions in Portugal?

Accepted Answer

No general structured e-invoicing mandate applies to ordinary domestic B2B transactions in the legislation reviewed. Businesses can use compliant paper or electronic invoices, with recipient acceptance for electronic issuance. Persons within Article 3 of Decree-Law 198/2012 must report covered document data by the fifth day of the following month.

Question 2

Are PDF invoices accepted as legal electronic invoices in Portugal?

Accepted Answer

Yes. Under Article 95(3) of Law 73-A/2025, PDF invoices are legally deemed to be electronic invoices for all tax purposes until 31 December 2026. A proposal in the draft 2027 State Budget would extend this treatment to 31 December 2027, but remains unapproved.

Question 3

When must smaller businesses comply with B2G e-invoicing?

Accepted Answer

Under Law 73-A/2025, Article 260(2), the transition lasts through 31 December 2026. Absent an amendment, covered micro, SME and public-entity suppliers enter the structured B2G obligation on 1 January 2027. Proposed 2027 Budget Article 138(2) would extend that date by one year.

Question 4

What is the deadline for communicating invoices to the AT?

Accepted Answer

Under Article 3(2) of Decree-Law 198/2012, covered document data is due by the fifth day of the following month. Article 3(9) also requires nil-issuance notification, subject to AT's exception for qualifying exclusive electronic green-receipt users.

Question 5

Does communicating invoice data to e-Fatura deliver the invoice to the buyer?

Accepted Answer

No. Communicating invoice data to AT does not itself deliver an invoice. Customer delivery is a separate obligation, subject to the statutory dispensation for qualifying consumer invoices under Article 8 of Decree-Law 28/2019.

Question 6

What are the ATCUD and QR code requirements?

Accepted Answer

Under Decree-Law 28/2019 and Portaria 195/2020, applicable documents require ATCUD, with QR-code display on covered visual representations. QR codes became mandatory from 1 January 2022. AT identifies 1 January 2023 as the ATCUD implementation date; its final deferral chain remains to be documented.

Question 7

What is the retention period for invoices in Portugal?

Accepted Answer

Under Article 19 of Decree-Law 28/2019, invoices and supporting records are generally retained for ten years, subject to special provisions or longer applicable tax-assessment periods. Electronic records may be stored in Portugal or another EU Member State; storage outside the European Union requires prior authorisation from the AT.

Question 8

What is the small-enterprise VAT exemption threshold in Portugal?

Accepted Answer

Under Article 53(1) CIVA, qualifying taxpayers with a Portuguese seat or domicile may benefit where preceding-year Portuguese turnover does not exceed €15,000. The €18,750 immediate-exit test applies in the statutory circumstances set out in Article 58; eligible EU businesses have a distinct cross-border regime under Article 53(2).

Portugal

Requisitos de facturación electrónica en Portugal

Requisitos de facturación electrónica en Portugal

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