Portugal

Portugal was one of the first countries to adopt SAF-T in 2008, and its implementation has evolved significantly since then.

Modules

The Portuguese system, known as SAF-T (PT), includes several modules:


Module	Description	Filing requirement	Deadline
Invoicing SAF-T	Invoice data and sales transactions	Mandatory monthly	5th day of the following month
Accounting SAF-T	General ledger, chart of accounts, and full accounting data	Mandatory annual and on-request	April 30 or June 15 (depending on fiscal year-end)
Transport documents	Data related to goods movement	Mandatory real-time	Before goods movement

Note:

Portugal has one of the most comprehensive SAF-T implementations in Europe, requiring both regular submissions and certified software for invoice generation. The system continues to evolve with regular updates to requirements and deadlines.

Possible penalties

Non-compliance with Portuguese SAF-T requirements can result in significant penalties:

Failure to submit: Fines up to €5,000
Late submission: Penalties calculated based on the delay period
Accounting record delays (over 90 days): Fines up to €5,000
Using non-certified software: Administrative penalties and potential tax adjustments

Special considerations

Non-residents

Non-resident entities registered for VAT in Portugal are required to comply with the invoicing SAF-T reporting obligations. Foreign businesses must use certified billing software and submit monthly SAF-T files for invoices with Portuguese VAT. However, the accounting SAF-T obligation generally applies only to established companies.

Small businesses

All businesses with Portuguese VAT registration must comply with the invoicing SAF-T requirement, regardless of size. For accounting SAF-T, businesses must submit if they are subject to corporate income tax (IRC) or personal income tax (IRS) with organized accounting.

Industry-specific requirements

While most requirements apply across all sectors, certain industries may have specific adaptations:

Retail: Special considerations for point-of-sale systems
Public events: Exemptions for certain ticket sales (though nil reports still required)
Financial services: Adjusted reporting requirements

SAF-T (PT) file structure

The Portuguese SAF-T file consists of the following main sections:

Header section
- Basic information about the reporting entity
- Tax identification details
- Reporting period information
- Software certification information
- Contact details
Master files section
- Chart of accounts ("taxonomías")
- Customer and supplier master data
- Product/service catalog
- Tax tables
- Payment methods
General ledger entries section
- Journal entries
- Transaction details
- Account movements
- Opening and closing balances
Source documents section
- Sales invoices with detailed line items
- Purchase invoices
- Payment information
- Movement of goods
- Working documents
Portugal-specific requirements
- QR codes on invoices
- Sequential document numbering
- Document series management
- Certified software requirements

The file must be generated in XML format according to the specifications set out in Portaria No. 321-A/2007 and subsequent updates. It must be produced by certified software approved by the Autoridade Tributária e Aduaneira (AT).

Submission requirements

Deadlines

Portugal has strict deadlines for different SAF-T modules:

Invoicing SAF-T: Must be submitted by the 5th day of the month following the reporting period. The authorities previously allowed submission by the 8th day, but from 2024 the official 5th-day deadline is being enforced.
Accounting SAF-T: Annual submission with deadlines based on the business type:
- By April 30 for personal income taxpayers (IRS) with organized accounts and corporate income taxpayers (IRC) required to have their accounts approved by March 31
- By June 15 for other taxpayers
Transport documents: Must be submitted before any goods movement begins

Missing these deadlines can trigger immediate penalties and increased scrutiny from tax authorities.

Filing formats & methods

File format: XML following Portuguese technical specifications
Character encoding: UTF-8
Submission methods:
1. E-Fatura portal: Primary submission channel for manual uploads
2. Direct transmission: Automated submission from certified software
3. API integration: For businesses with high transaction volumes

Note:

All files must be generated using certified software approved by the Portuguese tax authorities. This certification ensures that the software meets security and compliance standards for the automated generation and submission of SAF-T files.

Authentication

Portuguese SAF-T files must be authenticated using:

Certified software: Files must be generated by AT-approved software
Digital signatures: Files include digital authentication elements
Sequential controls: Each invoice must incorporate elements from previous transactions in a control chain

From Beginning January 1, 2026, a qualified electronic signature will be mandatory for all invoices (currently postponed from earlier implementation dates).

How to file

Use certified billing software.
- Ensure your software is certified by the Portuguese Tax Authority (AT).
- Configure the software with correct company information and tax settings.
- Implement proper document series and sequential numbering.
Generate the SAF-T file.
- Extract the required data from your certified software.
- Ensure all mandatory fields are correctly populated.
- Verify the XML structure complies with current specifications.
Validate the file.
- Check for structural and logical errors.
- Verify tax code assignments.
- Ensure all required elements are present.
- Confirm sequential integrity of documents.
Submit using Sovos SAF-T (most common).
- Log in to your Sovos SAF-T account.
- Go to the "Portugal SAF-T" submission section.
- Select the reporting period and upload your validated file.
- Review the pre-submission validation results.
- Apply the required digital signature through the platform.
- Click Submit to AT to transmit directly to the tax authority.
- Save the submission confirmation and tracking ID.
Alternative filing methods
- Direct E-Fatura portal: Manual upload through the Portuguese tax portal.
- API integration: For high-volume automated submissions directly from ERP systems.
- Third-party filing services: Other service providers offering SAF-T submission capabilities.
Maintain records of submission.
- Save confirmation of successful submission.
- Archive the submitted file.
- Retain all supporting documentation.
- Document any issues or special circumstances.

Confirmation and follow-up

Upon submission, you will receive an official receipt confirmation from the Portuguese Tax Authority (AT). This receipt is your legal proof of submission. Initial acceptance only confirms receipt, not data accuracy. There is no subsequent "approval" notification - you will only hear from authorities if there is an issue.

Post-submission process

The system performs automated validation checks
Cross-checking with other taxpayers' submissions may occur
Validation issues can result in rejection notices or requests for clarification

Response requirements

Respond to any official inquiries within the specified timeframe (typically 10 days). Corrections must be submitted as complete new files, not just the corrected transactions. Each correction must be marked as a correction with reference to the original submission.

Archive expectations

All supporting documents and underlying data must be retained according to Portuguese document retention requirements for a period of 10 years from the end of the fiscal year. Electronic records must remain accessible throughout this period, with systems designed to maintain uninterrupted access to historical data, even through system changes or upgrades.

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