Like other EU countries, Portugal has also regulated electronic invoices within the framework of EU Directive 2014/55. The entity that manages and coordinates the e-billing process is the ESPAP (Public Administration Shared Service Asset) set by the Ministry of Finance, Infrastructure and Housing. ESPAP coordinates the implementation of electronic invoices (FE-AP) in public administration. The use of electronic invoices in public contracts is gradually being made by the public and joint contractors. Micro, small and medium-sized enterprises were defined in accordance with Recommendation 2003/361 / EC of the European Commission of May 6, 2003. There is no specific invoice format. Interested parties can agree to use existing standards (EDIFACT, X12, XML).

What is SAF-T?

The SAF-T is a specification for a computer-readable file that transfers accounting data from the original accounting system into a predefined format derived from XML and makes it available for tax authorities for external auditing. The SAF-T (PT) file is intended to facilitate the collection of relevant tax data in electronic form by tax inspectors to aid taxpayers’ tax returns and/or analyze accounting records. In this regard, the SAF-T (PT) document requires an XML structure. There is no specific format for invoice status. Interested parties can agree to use existing standards (EDIFACT, X12, XML). SAF-T must be manufactured on a computer system approved by the Portuguese Tax and Customs Administration (Autoridade Tributária e Aduaneira – AT). It must be declared through public network services. The invoice to be sent to the customer must contain the SAF-T file and a unique code that was received from AT with the response. This code contains the signature of the previous invoice so that invoices are guaranteed one after the other. It is possible to summarize how SAF-T (PT) works: sales invoices (documentos comerciais a clientes), transport documents (documentos de transport), and customer payments are recorded directly in the accounting system. A standard SAF-T (PT) file in XML format is created from the data processed in the accounting system. This file is the source for the tax return. All of this information is sent to the last AT. Sales are transmitted to AT via the finance portal (Portal das Finanças). Transport documents (transport documents: Guia de Remessa, Guia de Transporte, invoice) are sent to AT after a standard SAF-T (PT) file has been created in XML format.

Transition dates to the electronic invoice application

  • Large companies (P> 250 people): The use of the electronic invoice is not mandatory until 01/01/2021. After 01/01/2021, e-invoices are mandatory.

  • Medium-sized companies (250 >P ≥ 50 people) and small businesses (50 > P ≥ 10 people): The use of the electronic invoice is not mandatory until July 1st, 2021. After July 1, 2021, e-invoices are mandatory.

  • Small businesses (P <10 people) and public institutions: The use of e-invoices is not mandatory until January 1st, 2022. After 01.01.2022, e-invoices are mandatory.

The 2019 budget proposal report highlighted the strategic dimension of the transition to e-invoicing for public administration. It is predicted that electronic invoicing will add to the program of digital transformation. In this context, the standardization, optimization, and automation of spending and income cycles occurs in both ways.

Public supply companies must apply for digital access to the portal BASE application (Plataforma Eletronica de Compras – EMEL), which ESPAP puts into operation when creating e-invoices. In addition, transactions related to electronic invoices and electronic transport documents are carried out on the general website of https://faturas.portaldasfinancas.gov.pt/.

Registration takes place in order to log into Portal das Finanças.

Invoice upload in X12, EDIFACT or XML format

SAF-T PT file (Portugal version)

According to the provisions of Decree No. 14-A / 2020, public administration suppliers must send their invoices in UBL 2.1-CIUS PT format according to the specified format. In this context;

  • Large companies through January 1, 2021
  • Small and medium-sized businesses by July 1, 2021
  • Until January 1, 2022, micro-enterprises and public institutions as contracting authorities cannot receive invoices in a format other than the European standard UBL 2.1-CIUS PT established by the Portuguese government.

All public contractors are required to receive and process electronic invoices since April 18, 2020, and must ensure that invoice documents are only received, processed, and forwarded in electronic form. ESPAP provides a solution for the implementation of FE-AP that can be used by all public institutions through voluntary membership by accepting the government and public institutions as directly affiliated organizations.

We support our customers with the Melasoft SAP e-invoice solution, with which they can manage e-invoice processes within SAP, which is fully integrated into SAF-T PT, which is offered by the Portuguese Tax and Customs Administration.