Portugal FAQ

Frequently asked questions about invoicing compliance in Portugal

Compliance questions

What invoicing rules apply across all systems in Portugal?

All invoices issued in Portugal must include a unique sequential number, a series identifier, an ATCUD code (Article 35-A CIVA), and a QR code (Portaria 195/2020). Software must be certified by the Autoridade Tributária — Invopop is certified.

Who can act as a supplier in Portugal?

Any entity with a Portuguese NIF — companies, sole traders, and freelancers. NIFs starting with 1, 2, or 3 are individuals (autónomos); NIFs starting with 5 are legal entities, which require additional registration metadata (share capital, commercial registry).

What are the legal obligations for receiving invoices in Portugal?

Recipients must verify the QR/ATCUD on each invoice via AT’s e-fatura portal and retain the document for 10 years (Article 123 CIVA). Auto-classification of received invoices into expense categories happens through e-fatura.

What periodic reporting obligations exist in Portugal?

Monthly or quarterly IVA periódica plus the annual IES (Informação Empresarial Simplificada). Invoice-level data is reported continuously through real-time submission or monthly SAF-T export — both feed AT’s e-fatura system automatically.

What is supplier registration information in invoices and other documents?

Supplier registration information includes the company’s share capital, the commercial registry office, and optionally the NIF used during registration. Portuguese law requires this information to appear on all printed fiscal documents, including PDFs.

When is it mandatory?

Registration information is mandatory for companies and legal entities. However, self-employed individuals and freelancers (whose NIF starts with 1, 2, or 3) are exempt from this requirement, as they typically do not have formal registration details.

What about the “other” field?

The other field is optional and can be used to specify the NIF of the company when it was registered if different from the current one.

Are there special supplier obligations under AT?

The supplier must use certified billing software, register their issuance series with AT, and choose a reporting model (monthly SAF-T or real-time). Self-employed taxpayers (NIF starting 1/2/3) are exempt from supplier registration metadata; companies must declare share capital and commercial registry.

What reporting obligations does AT impose?

Either real-time per-invoice transmission or monthly SAF-T export by the 5th of the following month. Both satisfy the reporting obligation under Portaria 195/2020 — the choice is operational.

Invoicing questions

Should our customers upload their SAF-T files manually?

In Portugal, fiscally relevant documents issued through invoicing software must be reported to the Tax Authority (AT). There are two possible reporting models:

1. SAF-T monthly export – a single XML file including all documents for the month. This file is generated by the invoicing software and then uploaded manually to the AT portal, as there is no API available for submitting it automatically.
2. Real-time transmission – instead of a monthly file, each invoice is sent individually to the AT at the time of issuance, using the authority’s API.

Whether one model or the other is used usually depends on the issuer’s accountant’s preference (who typically uploads the SAF-T monthly report should they choose that model). Invopop’s AT Portugal app supports both reporting methods, so each supplier can pick the one that best fits their needs.

How do I configure my workspace for Portuguese invoicing?

Install the AT Portugal app, register the supplier with their NIF, and pick a reporting model (monthly SAF-T or real-time submission). Run invoices through the AT Issue Invoice workflow — Invopop generates the ATCUD, QR, and signature automatically.

Why does recording fail with 'payable: too high according to Artigo 40.º do CIVA'?

When issuing in Portugal you may see an error similar to:

recording envelope: totals: (payable: too high according to Artigo 40.º do CIVA.)

What it means: Article 40 of the Portuguese VAT Code (Código do IVA) sets limits and rules for simplified invoices (faturas simplificadas). If the payable amount exceeds what is allowed for a simplified invoice in your situation, the rules effectively require a full invoice (fatura completa) with proper buyer identification—not an anonymous or minimal customer.

What to do:

• Treat the document as a full invoice and supply real customer tax data when you have it.
• If you do not have the buyer’s tax information, Portuguese practice allows the generic retail customer: set the customer name to Consumidor final and the tax ID to 999999990.
• For transactions above €1,000, the law also expects name and address on the document. The AT may not always reject submissions that omit some of that detail, but you should follow the rule for full compliance.

Adjust your GOBL customer block (or equivalent) accordingly and re-run the workflow.

Where do I find Portugal-specific GOBL documentation?

See the Portugal tax regime in GOBL for tax categories, NIF rules, and AT-specific extensions. The pt-saft-v1 addon documents fields required by the SAF-T schema.

AT (SAF-T)

How often must I submit AT reports?

Real-time model: per invoice. SAF-T model: once per month, by the 5th of the following month. The choice is set at supplier registration and can be changed by re-registering.

How do I schedule periodic reports for Portugal?

For invoice-level reporting, choose the model at supplier registration: real-time (Invopop submits per invoice) or monthly SAF-T (Invopop generates the file by the 5th of the following month, accountant uploads). Periodic VAT and IES are filed separately by the accountant.

What format does AT expect for periodic reports?

Monthly SAF-T-PT XML uploaded to AT’s portal (no API for this), or real-time WebService XML calls per invoice. Both follow the same SAF-T schema; real-time submits one document at a time, SAF-T submits an aggregated file covering the month.

Registering supplier questions

How do I register a supplier with AT?

Run the AT Register Supplier workflow with the supplier’s NIF and chosen reporting model. Invopop registers the issuance series with AT and generates the ATCUD prefix to be embedded in every issued document.

What credentials does AT require to authenticate a supplier?

For real-time submission, an AT API username/password is required (issued through the AT portal). For SAF-T monthly export, no live credentials are needed — only the supplier’s NIF and series registration.

How are supplier credentials stored in Invopop for Portugal?

For real-time submission, Invopop stores AT API credentials encrypted at rest. For SAF-T export model, no live credentials are needed — the supplier (or their accountant) downloads the SAF-T file and uploads it manually to AT’s portal.

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