Portugal
PTPortugal combines a phased public-procurement e-invoicing obligation through eSPap's FE-AP with tax controls on every invoice, including certified software, ATCUD and QR codes, and monthly invoice reporting.
Guide reviewed .
Invoicing and electronic documents
FE-AP (Fatura Eletrónica na Administração Pública)
eSPap's solution for public bodies to receive and process invoices and corrective documents under public contracts. Suppliers join through an onboarding process and send by webservices or AS2 through a broker; the eSPap pages reviewed do not describe Peppol as an FE-AP channel.
CIUS-PT in UBL 2.1 or UN/CEFACT CII, compliant with EN 16931 · Official source: eSPap · FE-AP frequently asked questions
Microportal FE-AP
A simplified eSPap application for small suppliers issuing fewer than 250 documents a year to public bodies that receive through FE-AP.
CIUS-PT documents entered in the portal · Official source: eSPap · FE-AP frequently asked questions
Invoice communication to the tax authority (SAF-T (PT))
Resident taxpayers report the data of all B2B, B2C and B2G invoices to the Tax and Customs Authority (AT) monthly, by SAF-T (PT) file or real-time web service. This is reporting, not invoice delivery.
SAF-T (PT) XML or web service · Official source: European Commission · eInvoicing in Portugal
Treat public-sector delivery and tax compliance as separate jobs. A CIUS-PT invoice delivered to FE-AP must still come from certified software, carry the ATCUD and QR code, and be reported to AT. Before sending, check that the public buyer receives through FE-AP and which channel applies. See eSPap's FAQ.
Two dates depend on the 2027 State Budget, still a proposal when this guide was reviewed. Current law sets 1 January 2027 for the SME start in public procurement and 31 December 2026 as the last day of PDF acceptance; the government's proposal would push each back a year. eSPap lists the autonomous regions of the Azores and Madeira among the public contracting authorities, so the receiving obligation covers their bodies too.
Legal guide
B2G · public bodies receiving
MandatoryAll public contracting authorities under article 3 of the Public Contracts Code must receive and process electronic invoices, including the State, autonomous regions, local authorities and public institutes.
Official source: eSPap · FE-AP frequently asked questionsB2G · suppliers sending
Large companies since 2021; others from 1 January 2027Large companies (more than 250 staff, or turnover above €50 million or a balance sheet above €43 million) must issue e-invoices under public contracts since 1 January 2021. SMEs, micro-enterprises and public entities as co-contractors follow on 1 January 2027 under the 2026 State Budget Law. Simplified direct awards and secret contracts are excepted.
Official source: eSPap · FE-AP suppliers and e-invoicing deadlinesB2G · proposed postponement
ProposedThe 2027 State Budget proposal would extend the exemption in article 9(4) of Decree-Law 111-B/2017 to 31 December 2027, moving the SME start back by a year. It is not yet law.
Official source: Government of Portugal · 2027 State Budget proposal (law text)Electronic invoices and signatures
Qualified signature, seal or EDIAn invoice may be issued electronically if the recipient accepts. Authenticity and integrity are guaranteed by, among other methods, a qualified electronic signature, a qualified electronic seal or an EDI agreement. For FE-AP, webservice documents need an XAdES signature with a qualified certificate or seal; AS2 relies on transport signing.
Official source: Procuradoria-Geral Regional de Lisboa · Decree-Law 28/2019 on invoices, consolidatedPDF invoices
Accepted until 31 December 2026The 2026 State Budget Law (Law 73-A/2025, article 95(3)) accepts PDF invoices as electronic invoices for all tax purposes until 31 December 2026. The 2027 State Budget proposal would extend this to 31 December 2027.
Official source: Procuradoria-Geral Regional de Lisboa · Law 73-A/2025, 2026 State BudgetATCUD and QR code
MandatoryInvoices and other tax-relevant documents must carry a QR code and a unique document code (ATCUD). The ATCUD combines a validation code that AT assigns to each communicated document series with the document's number.
Official source: Procuradoria-Geral Regional de Lisboa · Decree-Law 28/2019 on invoices, consolidatedE-reporting · invoice data
MonthlyInvoice data have been reported monthly since 2013; from 1 January 2023 the deadline is the 5th of the following month.
Official source: European Commission · eInvoicing in PortugalSAF-T (PT) accounting file
From periods of 2027, filed in 2028Under the 2026 State Budget Law, the accounting SAF-T (PT) file applies to periods from 2027, submitted from 2028. The 2027 budget proposal would move this to periods from 2028, submitted from 2029.
Official source: Procuradoria-Geral Regional de Lisboa · Law 73-A/2025, 2026 State BudgetB2B · business invoices
No structured e-invoicing obligation found in the sources reviewedThe European Commission records no B2B or B2C e-invoicing mandate; parties may use paper or PDF invoices if both agree. The tax rules on certified software, ATCUD, QR codes and invoice reporting still apply.
Official source: European Commission · eInvoicing in Portugal
Timeline
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Public bodies receive e-invoices
Historical. Public contracting authorities must receive and process electronic invoices.
Official source: eSPap · FE-AP frequently asked questions -
Remaining public bodies receive e-invoices
Historical. The extended deadline ends for contracting authorities outside paragraphs a) and d) of article 2(1) of the Public Contracts Code.
Official source: eSPap · FE-AP frequently asked questions -
Large suppliers issue e-invoices
Historical. Large companies must send e-invoices under public contracts.
Official source: eSPap · FE-AP suppliers and e-invoicing deadlines -
QR code on invoices
Historical. The QR code becomes mandatory on documents from certified invoicing software.
Official source: Ordem dos Contabilistas Certificados (professional body) · QR code, ATCUD and series communication dates (2021) -
ATCUD and series communication
Historical. Document series must be communicated to AT and the ATCUD printed on invoices.
Official source: Ordem dos Contabilistas Certificados (professional body) · QR code, ATCUD and series communication dates (2021) - Upcoming at review
PDF acceptance ends under current law
Last day on which PDF invoices count as electronic invoices under the 2026 State Budget Law; a proposed extension runs to 31 December 2027.
Official source: Procuradoria-Geral Regional de Lisboa · Law 73-A/2025, 2026 State Budget - Upcoming at review
SMEs issue B2G e-invoices under current law
Upcoming under current law. SMEs, micro-enterprises and public co-contractors must issue e-invoices; the 2027 budget proposal would defer this by a year.
Official source: eSPap · FE-AP suppliers and e-invoicing deadlines
Peppol in Portugal
- Directory participants
- 158
- Document families
- 9
Peppol Authority: eSPap (Entidade de Serviços Partilhados da Administração Pública).
1 certified service provider based in Portugal.
Peppol Directory data as of .
How to read these numbersDocuments on Peppol
- 124 participants
- 122 participants
- ApplicationResponse65 participants
- 15 participants
- 7 participants
- 7 participants
- CrossIndustryInvoice6 participants
- 6 participants
- 1 participant
Registrations over time
Peppol Directory data as of .
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Registration dates in the current Directory snapshot.