E-invoicing in Portugal

Who is in scope

All VAT-registered businesses including non-residents for SAF-T billing; the B2G obligation binds public-sector suppliers; the QES rule catches anyone still emailing PDF invoices. There is NO domestic B2B structured e-invoicing mandate.

Key dates

• 1 Jan 2021 B2G e-invoicing mandatory for large enterprises.
• 1 Jan 2023 ATCUD unique document code and QR code mandatory on all invoices.
• 1 Jan 2025 / 1 Jan 2026 B2G extended to SMEs and micro-enterprises — sources differ on which date finally applied.
• 31 Dec 2026 End of the transitional regime: PDF invoices from certified software carrying ATCUD and QR remain valid without a qualified electronic signature only until this date.
• 1 Jan 2027 Qualified electronic signature (QES) mandatory on PDF invoices in B2B and B2C, unless another accepted structured format is used.
• 2028 First mandatory annual SAF-T accounting file due (reporting year disputed — see watch_out).

Sources

1 of 4 are primary sources. Mandate dates move — treat this page as a starting point and confirm against the primary source before committing a plan.

• primary European Commission, DIGITAL building blocks last updated 2025-08-14 — SUPERSEDED, still states QES from 1 Jan 2026
• secondary KPMG 2025-12-05
• secondary RTC Suite 2026-05-15
• secondary VATupdate 2026-05-29