Further Changes to e-Invoicing Mandate in Portugal – Update from July 2021

In common with the other European states, the Portuguese government has also introduced measures to cushion their tax payers from the negative impact of the COVID-19 pandemic. One of these is to postpone the deadline for making qualified electronic signatures (QES) on pdf invoices compulsory.

This post is an update to our blog post new deadlines for the B2G e-invoicing mandate in Portugal of 23rd April 2020.

On 22nd April 2021, the Portuguese Ministry of Finance passed the legislative bill Despacho Nº 133/2021-XXII, which stipulates the use of a QES on e-invoices not sent through electronic data exchange (EDI), essentially pdf invoices. This bill will now come into force on 1st October 2021, three months later than originally planned. Therefore, from 1st October 2021, any e-invoices sent in pdf format yet not through EDI need to be signed with a qualified electronic signature to be valid for tax purposes. This stipulation applies to e-invoices from all arenas, whether B2C, B2B or B2G.

Are there any e-Invoicing platforms for Portugal?

In Portugal, the eSPAP (Entidade de Serviços Partilhados da Administração Pública) is a central coordinating body which acts as a middleman between suppliers and public administration, sending and receiving e-invoices and their accompanying documents in accordance with European legislation. E-invoices to government entities or public agencies such as IAPMEI, INEM, IPDJ, ISS and eSPAP itself are therefore sent over eSPAP’s platform Fatura Eletrónica na Administração Pública (FE-AP).

Public administration bodies in Portugal are also able to use the Portal BASE platform for contracts which are put out to public tender. The portal uses public e-procurement solutions which help you manage the various administrative steps through the whole public procurement process, including e-invoicing. At present, there are five public e-procurement management solutions which are certified for Portal BASE:

• acinGov,
• anoGov,
• ComprasPT,
• saphetygov,
• VORTAL Gov.

These e-procurement solutions each guarantee full integration into an ERP system and a seamless process allowing e-invoices to be created, sent and archived. Public sector purchasers should therefore invest in a certified e-procurement solution. However, parties are free to choose which certified solution they wish to implement.

Alongside the five certified providers, there are further providers who offer e-invoicing services which help suppliers to public agencies to send and receive e-invoices which comply with the eSPAP standards. These platforms also offer EDI and are set up for cross-border e-invoicing, including the various international VAT requirements. These platforms are recognised by the Portuguese tax authorities as an e-invoicing application and that they meet the eSPAP standards.

Although a high number of invoice recipients in Portuguese public administration are probably already registered with eSPAP, the invoicer should still find check which e-procurement solution is actually used by its customer.

How can SEEBURGER help you meet the current Portuguese invoicing requirements?

We are an established, experienced provider of E-Invoicing-Cloud-Services and your one stop shop for e-invoicing solutions to meet the specific global and local legislation of countries within Europe and beyond. We offer strong local support to support both our multinational customers and our Portugal-based customers with various e-invoicing services such as CIUS-PT via various platforms, including eSPAP. SEEBURGER Global E-Invoicing Services can be integrated into the eDocument Cockpit in SAP ECC or SAP S/4HANA, as well as any other enterprise resource planning system.