Portugal AT Updates e-Fatura Rules: What Foreign Businesses with Portuguese VAT Must Know
Portugal's Tax and Customs Authority (AT) has updated e-Fatura certification requirements for 2026, tightening rules on certified invoicing software for all businesses — including foreign companies with Portuguese VAT registrations.
Portugal has operated one of Europe's most mature e-invoicing systems for over a decade. The AT (Autoridade Tributária e Aduaneira) requires all businesses with a Portuguese VAT registration (NIF) to issue invoices through AT-certified software and to report invoice data to the e-Fatura portal in real time.
In May 2026, the AT published updated technical specifications for certified invoicing software, with important changes affecting both domestic Portuguese businesses and foreign companies with Portuguese VAT registrations.
How Portugal's System Works
Portugal's approach differs from Germany's (format-based) or Italy's (clearing-house SDI):
- Certified software only: You must use AT-certified invoicing software. Using uncertified software — even to generate PDFs — is a legal violation subject to penalties.
- SAF-T PT reporting: All invoice data must be exported in SAF-T PT (Standard Audit File for Tax) format and submitted to the AT portal monthly.
- e-Fatura real-time feed: For consumer transactions (B2C), invoice data is sent to the e-Fatura.irs.pt portal in real time.
- QR code on every invoice: Since 2021, all Portuguese invoices must carry a QR code containing hash-verified invoice data.
- ATCUD code: Since 2023, all invoices must include an ATCUD code (a unique AT-assigned invoice code replacing the older invoice series registration system).
What Changed in the May 2026 Update
The AT's updated certification specification (Portaria 195/2026, May 2026) introduces:
Updated SAF-T PT Schema (v1.04)
The SAF-T PT export schema has been updated to v1.04, adding:
- EU VAT ID of foreign B2B customers as a mandatory field (aligning with ViDA)
- Peppol ID as an optional field for businesses using Peppol alongside the AT system
- Updated country codes (ISO 3166-1 alpha-2) and currency code requirements
ATCUD for Subsidiary Documents
The ATCUD requirement now extends to all subsidiary documents — delivery notes, pro-forma invoices, and receipt acknowledgements must also carry the AT-assigned ATCUD code.
Foreign Business Deadline
Foreign businesses with Portuguese NIF registrations who have not yet migrated to AT-certified software have a final compliance deadline of 31 December 2026. After this date, ATCUD codes will not be issued to uncertified software.
For Foreign Businesses Operating in Portugal
If your business has a Portuguese NIF for any reason — a subsidiary, a permanent establishment, a Portuguese customer base that requires Portuguese invoices — you must use AT-certified software. The updated rules apply to you equally.
Certified software options for foreign businesses:
- Sage Business Cloud Portugal — internationally accessible, Portuguese tax module
- Primavera BSS — leading Portuguese ERP, available in English
- PHC Software — popular Portuguese accounting with international modules
- Moloni — modern cloud invoicing, widely used by international businesses operating in Portugal
Penalties
Non-compliance with AT certification requirements carries penalties of €375–€18,750 per infraction — one of the highest penalty ranges in the EU for invoicing software violations.
Source
AT Portaria 195/2026 and AT certified software registry: at.gov.pt
