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Electronic Invoicing in Portugal: A Cornerstone of Digital Transformation

Electronic invoicing is increasingly recognized as a crucial element in Portugal's digital transformation of public administration, significantly impacting both the public and private sectors.

Portugal has postponed the implementation of mandatory B2G (Business-to-Government) e-invoicing requirements for small and medium-sized enterprises (SMEs). Originally scheduled for an earlier date, the new deadline for SMEs to comply with e-invoicing in B2G transactions is now January 1, 2026. This extension was formalized through recent legislative changes, specifically Decree-Law No. 13-A/2025, dated March 10, 2025. As a result, SMEs will be allowed to use alternative invoicing methods, apart from the structured CIUS-PT scheme, until December 31, 2025. This adjustment reflects the government's acknowledgment of the financial and technological challenges faced by SMEs, ensuring they have adequate time and resources to achieve full compliance.

The use of electronic invoicing is mandatory for transactions between suppliers and public administrations. In contrast, for private companies, adoption remains voluntary, allowing them the option to opt into this electronic invoicing system.

Key Aspects of Electronic Invoicing

Archiving
Invoices must be archived for a minimum of ten years by both the issuer and the recipient.

 Administrative Procedures
If a public entity is associated with the eSPAP platform, its suppliers are required to register in advance and conduct necessary connection tests. Suppliers connected to other public entities must follow their specific platform protocols.

Format Requirements
The public administration accepts invoices in UBL 2.1 'CIUS-PT' and CEFACT 'CIUS-PT' formats, both based on XML. An electronic signature is also mandatory for invoices addressed to public administrations.

Penalties for Non-Compliance
Penalties associated with non-compliance with electronic invoicing and budgetary regulations are clearly defined within this framework, encompassing potential financial penalties and withholding actions. Organizations failing to adhere to invoicing regulations may face significant financial repercussions, underscoring the need for timely implementation.

Conclusion

Portugal's recent legislative advancements and support for SMEs demonstrate a strategic commitment to digitalization. By addressing the unique needs of SMEs and promoting transparency and efficiency, Portugal sets an important precedent for the adoption of electronic invoicing in both public and private sectors. Through careful planning and adherence to these regulations, Portuguese companies and public entities can effectively leverage the substantial benefits of e-invoicing as part of their digital transformation initiatives.

How Can KGT Support You?

KGT has created an SAP-integrated e-invoicing add-on solution for Portugal, featuring outbound and inbound functionalities to meet tax reporting requirements. This add-on includes a data extractor and a cockpit for generating periodic electronic invoices in the legal format and controls before submission. When SAP DRC launched Portuguese e-invoicing solution as part of its e-document offerings, KGT emerged as a leading consultancy firm for SAP DRC and tax services. Recognized as an SAP DRC partner for Portuguese e-invoicing services, KGT is one of SAP's recommended implementation partners for this solution. We provide comprehensive support, including installation, configuration, customization, and training, to help you maximize the long-term value of your SAP DRC investment.

KGT is a SAP partner for PE services and SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at: https://partnerfinder.sap.com/profile/0001925409