Portugal FAQ

Frequently asked questions about invoicing compliance in Portugal

Should our customers upload their SAF-T files manually?

In Portugal, fiscally relevant documents issued through invoicing software must be reported to the Tax Authority (AT). There are two possible reporting models:

1. SAF-T monthly export – a single XML file including all documents for the month. This file is generated by the invoicing software and then uploaded manually to the AT portal, as there is no API available for submitting it automatically.
2. Real-time transmission – instead of a monthly file, each invoice is sent individually to the AT at the time of issuance, using the authority’s API.

Whether one model or the other is used usually depends on the issuer’s accountant’s preference (who typically uploads the SAF-T monthly report should they choose that model). Invopop’s AT Portugal app supports both reporting methods, so each supplier can pick the one that best fits their needs.

What is supplier registration information in invoices and other documents?

Supplier registration information includes the company’s share capital, the commercial registry office, and optionally the NIF used during registration. Portuguese law requires this information to appear on all printed fiscal documents, including PDFs.

When is it mandatory?

Registration information is mandatory for companies and legal entities. However, self-employed individuals and freelancers (whose NIF starts with 1, 2, or 3) are exempt from this requirement, as they typically do not have formal registration details.

What about the “other” field?

The other field is optional and can be used to specify the NIF of the company when it was registered if different from the current one.

Why does recording fail with 'payable: too high according to Artigo 40.º do CIVA'?

When issuing in Portugal you may see an error similar to:

recording envelope: totals: (payable: too high according to Artigo 40.º do CIVA.)

What it means: Article 40 of the Portuguese VAT Code (Código do IVA) sets limits and rules for simplified invoices (faturas simplificadas). If the payable amount exceeds what is allowed for a simplified invoice in your situation, the rules effectively require a full invoice (fatura completa) with proper buyer identification—not an anonymous or minimal customer.

What to do:

• Treat the document as a full invoice and supply real customer tax data when you have it.
• If you do not have the buyer’s tax information, Portuguese practice allows the generic retail customer: set the customer name to Consumidor final and the tax ID to 999999990.
• For transactions above €1,000, the law also expects name and address on the document. The AT may not always reject submissions that omit some of that detail, but you should follow the rule for full compliance.

Adjust your GOBL customer block (or equivalent) accordingly and re-run the workflow.

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