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This guide provides an overview of e-Invoicing requirements in Portugal, including the legal framework, the use of the eSPap – FE-AP network, compliance obligations, and key reporting considerations. It is intended to assist businesses that issue or receive invoices for transactions subject to Portuguese Value Added Tax (IVA).
Portugal has progressively digitised invoicing and reporting through a “hybrid” approach that combines mandatory certified invoicing software, mandatory periodic digital reporting, and mandatory e-Invoicing for public sector transactions. Since 2013, taxpayers have been required to transmit invoice data monthly to the Portuguese Tax Authority (Autoridade Tributária e Aduaneira).
The use of certified invoicing software has been mandated since 2020 to reduce fraud and improve auditability, supported by mechanisms such as QR codes and the unique document code (ATCUD). Portugal then introduced mandatory B2G e-Invoicing through the FE-AP platform (via eSPap), with phased implementation by business size (large companies first, then SMEs, then micro-entities). B2B and B2C e-Invoicing remains voluntary, but reporting and certified software obligations apply broadly above a turnover threshold.
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Examples include:
Late issuance of invoice/receipt: EUR 150–3,750.
Inaccurate/missing accounting or tax documentation: EUR 750–22,500.
Missing mandatory elements (e.g., QR code / ATCUD): EUR 200–1,000 per invoice.
Failure to use certified invoicing software/equipment: EUR 3,000–18,750.
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