Portugal was the first EU country to mandate e-invoicing at scale — as far back as 2013. More than a decade on, the e-fatura system is fully mature and still evolving. For any European company operating in Portugal through a subsidiary, a permanent establishment, or a local VAT number, the obligations are concrete, non-negotiable, and can derail an ERP deployment that hasn’t accounted for them.
This guide covers the regulatory landscape as it stands in 2026 and the major changes expected in 2027-2028, with a focus on what your ERP must actually support.
The e-fatura system: Europe’s e-invoicing pioneer since 2013
What is e-fatura?
e-fatura is the portal of the Autoridade Tributária e Aduaneira (AT) — Portugal’s tax authority — to which all VAT-registered companies in Portugal must transmit invoice data in near real time. The mechanism is built on the SAF-T (Standard Audit File for Tax) format, Portugal edition, known as SAF-T (PT).
Launched in January 2013, this system predated similar reforms in France (PDP 2026), Italy (SdI 2019), and Germany (XRechnung 2025) by several years. Portugal bet on total VAT transparency — and it paid off: VAT fraud has dropped significantly since the system went live, according to the Portuguese Ministry of Finance.
Who is in scope?
Every VAT-registered entity in Portugal, whether resident or non-resident. Since January 2023, this obligation has been explicitly extended to non-established companies that are registered for VAT in Portugal (Sovos, Billing SAF-T in Portugal: A New Obligation for Non-Residents).
In practice: if your Portuguese subsidiary, branch, or holding entity issues invoices in Portugal, it falls within scope.
The framework: AT-certified software + monthly SAF-T
Any invoicing software used in Portugal must be certified by the AT. This is not optional: uncertified software cannot legally issue valid invoices in Portugal. The certification requires, among other things:
- Generation of a SAF-T (PT) file compliant with the AT’s XML schema
- Cryptographic signing of tax documents (RSA)
- Automatic generation of an ATCUD (Código Único do Documento) for each fiscally relevant document
- Printing of an AT QR code on every paper or PDF invoice
- Full traceability with a complete audit trail
The AT publishes and maintains the official list of certified software.
SAF-T Portugal: the mandatory audit file
Structure and frequency
SAF-T (PT) comes in two variants:
SAF-T Invoicing (Type F) — monthly obligation: each month, by the 5th of the following month, VAT-registered companies must submit to the AT an XML file containing all invoices, credit notes, and debit notes issued during the month (Sovos Documentation Portugal). Until January 2023, the deadline was the 12th; it was brought forward to the 5th by ministerial order.
SAF-T Accounting (Type C) — annual obligation on the horizon: this file — containing full accounting data (general ledger, journals, trial balances) — was initially set for 2027, then pushed back to 2028 as part of the 2026 budget (RTC Suite, Portugal Postpones Again). The first effective submission will therefore cover the 2027 fiscal year, filed in 2028.
Comparison with France’s FEC and Luxembourg’s SAF-T
All three share the same OECD base standard (SAF-T), but implementations differ:
| SAF-T Portugal (PT) | France FEC | SAF-T Luxembourg | |
|---|---|---|---|
| Frequency | Monthly (invoicing) | On demand (audit) | Annual |
| Format | AT XML schema | Delimited CSV | LU XML schema |
| Scope | Invoices + accounting (future) | Accounting | Accounting |
| Submission | AT online portal | Tax inspection | Tax administration |
For multi-country groups, each entity carries its own compliance requirements: a generic localisation module does not automatically cover Portugal.
2026-2027 changes: what to watch
QES mandatory for PDFs from January 2027
Until 31 December 2026, a PDF sent by email retains legal validity as an electronic invoice, provided the issuer can guarantee its authenticity and integrity.
From 1 January 2027, any PDF used as a B2B e-invoice must be signed with a QES (Qualified Electronic Signature) compliant with the eIDAS regulation. The signature must be issued by a qualified trust service provider (Fiscal Solutions, Portugal Extends PDF e-Invoice Validity).
This requirement was enacted in the 2026 Finance Bill (Draft Law No. 37/XVII/1), voted by the Portuguese Parliament in November 2025.
In practice: if your ERP issues Portuguese invoices as PDFs, it will need to integrate a QES signing module or pass through a certified service provider before the end of 2026.
SAF-T Accounting delayed to 2028
The obligation to submit the annual SAF-T Accounting file — originally covering fiscal year 2025 (submission in 2026), then reframed as fiscal year 2026 (submission in 2027) — has been pushed back again: first fiscal year in scope = 2027, first effective submission = 2028 (RTC Suite).
This delay gives additional time to prepare ERP systems, but should not be read as an abandonment of the requirement. The trajectory is clearly towards full accounting transparency.
Peppol and B2G invoicing: infrastructure in place
Portugal has joined the Peppol network and deployed its national B2G platform FE-AP (managed by eSPap). Since 1 January 2024, all public sector suppliers — including SMEs and micro-enterprises — must issue structured invoices through this platform, in CIUS-PT (Portugal’s national adaptation of EN 16931) or Peppol BIS 3.0 format (European Commission eInvoicing Country Sheet Portugal 2024).
Large enterprises had this obligation from January 2021; SMEs joined from January 2022 (general public) and January 2024 (all entities). The Peppol network is therefore fully operational in Portugal for B2G — B2B remains outside the current e-fatura directive scope, but the regulatory trajectory points in that direction over the medium term.
ERP impact: what to verify
AT certification: the non-negotiable gateway
This is the first filter to apply. An ERP deployed in Portugal without AT certification cannot legally issue invoices. This applies equally to locally developed ERPs and to international ERPs with a Portugal localisation module.
Questions you must put to your vendor:
- Is the Portugal module AT-certified? What is the certification number?
- Does the certification cover the version currently installed at your subsidiary?
- Does the module automatically generate the ATCUD for each document?
- Is the AT QR code printed on both PDF and paper invoices?
- Is the SAF-T (PT) Invoicing file exportable in the correct schema for monthly submission?
Established local ERP vendors: Cegid PHC and Cegid Primavera
The two historical market leaders in Portuguese ERP are PHC Software and Primavera BSS, both now part of the Cegid group following acquisitions in 2023-2025. Cegid Portugal reported revenue of €85M in 2025, with a projection of €93.5M for 2026 (The Portugal Post, ERP Consolidation: What Cegid’s PHC Acquisition Means for SMEs).
Both platforms (now marketed as Cegid PHC CS and Cegid Primavera) are natively AT-certified and cover all Portuguese regulatory obligations out of the box: SAF-T, ATCUD, QR code, cryptographic signing.
For SMEs operating exclusively in Portugal, they represent the lowest regulatory risk.
Global ERP vendors: SAP, Oracle, Microsoft Dynamics
The major vendors offer Portugal localisation modules, but availability and update levels vary:
- SAP S/4HANA: Portugal localisation available, SAF-T (PT) supported via FI/SD modules — verify the version and patch level
- Microsoft Dynamics 365 Business Central: AT-certified Portugal localisation available in AppSource
- Oracle NetSuite: Portugal support via SuiteApp — verify valid AT certification
Absolute rule: ask your integrator or vendor for an up-to-date AT certification document, not just a commercial statement. AT certification is public and verifiable on the AT portal.
ERP deployed without a Portugal localisation
If your group is running a proprietary or non-AT-certified tool, two options:
- Compliance middleware: a third-party tool (EDICOM, Sovos, B2Brouter) connects to your ERP to handle AT certification, SAF-T generation, and AT submission. This adds a layer of complexity but allows you to keep the group ERP.
- Satellite local ERP: run Cegid PHC or Cegid Primavera for local invoicing, with integration back to the group ERP for financial consolidation.
Practical guide for a European subsidiary in Portugal
Minimum compliance checklist
Before deploying or going live with an ERP in Portugal, verify each of the following:
- The invoicing software is AT-certified (certification number verifiable at info.portaldasfinancas.gov.pt)
- ATCUD is generated automatically for each invoice, credit note, and debit note
- An AT QR code is printed on every tax document (PDF and paper)
- The SAF-T (PT) Type F file can be exported and submitted each month by the 5th
- A monthly submission process is in place (manual or automated)
- Document series are registered in the AT portal
- For B2G invoices: CIUS-PT or Peppol BIS 3.0 format via FE-AP
What to ask your integrator or vendor
- Provide the valid AT certification number for the deployed version
- Demonstrate ATCUD generation on a test invoice
- Show the SAF-T (PT) export and the submission process to the AT portal
- Confirm the update timeline for QES mandatory from January 2027
- Clarify the roadmap for SAF-T Accounting (first fiscal year: 2027, submission: 2028)
Upcoming deadlines calendar
| Date | Obligation |
|---|---|
| Monthly (5th of the month) | SAF-T (PT) Invoicing submission to AT |
| 31 December 2026 | Last date PDF invoices without QES are valid |
| 1 January 2027 | QES mandatory on all B2B PDF invoices |
| Fiscal year 2027 | First fiscal year subject to SAF-T Accounting |
| 2028 | First effective SAF-T Accounting submission |
Portugal is not an easy regulatory market. It is one of the most advanced in Europe for digital tax transparency. For a Portuguese subsidiary, e-fatura / SAF-T compliance is not an optional roadmap item — it is a condition of operation.
The good news: the infrastructure is mature, certified vendors are numerous, and the 2027-2028 timelines provide enough lead time to prepare — provided you start the project now rather than waiting until late 2026.
To explore the broader European regulatory context, read our complete guide to mandatory e-invoicing in Europe, our SAF-T and ERP digital tax compliance guide for Europe, and our Peppol analysis: interoperable e-invoicing across Europe.
