Portugal: Changes to E-invoicing Rules in 2021-2022

March 30, 2021

Portugal is developing and expanding the mandate of its electronic invoicing system. This is similar to reforms from the past few years in other European countries, such as Italy, which aim to close the VAT gap between expected and collected VAT revenue, and combat tax fraud. 

The Portuguese government has just issued new rules and regulations for electronic and print invoices. In this article, we’ll look at some of the most recent changes, whose details are important for all businesses operating in Portugal. The changes are related to B2G (business-to-government) e-invoicing and to the addition of an ATCUD and QR code to all invoices.


What’s Changing for B2G Transactions?

One of the most important changes concerns B2G (business-to-government) transactions: since January 1, 2021, electronic invoicing for B2G transactions has become mandatory in Portugal for large companies. Large companies are defined as companies with over 250 employees, an annual balance sheet of 43 million EUR (or more), and an annual turnover of over 50 million EUR. 

The Portuguese institution responsible for the rollout of the B2G e-invoicing system is called eSPap, Entidade de Servi√ßos Partilhados da Administra√ß√£o P√ļblica, the Office for Public Administration of Shared Services. The eSPap coordinates the transfer of invoices between companies and the public sector. Most government institutions were connected to the eSPap portal in the past few months, in preparation for the reform.

Starting from July 1, 2021, small and medium-sized enterprises will also need to invoice all B2G transactions electronically. The same will apply for micro-enterprises after January 1, 2022. 


When Will ATCUD and QR Codes Become Mandatory? 

In contrast to B2G transactions, the implementation of the ATCUD code, which is a unique ID number that companies need to include to each invoice, has been postponed. 

The ATCUD code will become mandatory after January 1, 2022, and not from January 1, 2021, which is when it was originally scheduled. The government has decided to delay the implementation of the ATCUD code in view of the  ongoing pandemic, allowing companies to allocate their resources to more urgent matters. Companies will need to apply for their ATCUD code in 2021 and obtain it before 2022. After January 1, 2022, the Portuguese tax authorities will not accept and will not deem as valid invoices without an ATCUD code. 

The obligation to include a QR code remains, however: all invoices (i.e. both electronic and printed invoices) need to have a mandatory QR code, starting from January 1, 2021.

The government’s goal of adding QR and ATCUD codes to all invoices is to simplify communication with tax authorities, and also to be more efficient in preventing tax fraud. 


Use Fonoa To Report Sales Transactions

Fonoa, as one of the certified billing providers in Portugal can help you ensure that your sales transactions are reported in real time to tax authorities, immediately and without human intervention.



If your business is affected by these regulations in Portugal, reach out to us, and we will help you automate the invoice reporting process in Portugal.