🇵🇹 Portugal

Authority: AT (Autoridade Tributária e Aduaneira).

Portugal has no dedicated e-invoicing channel or format in this app, and one specific legal requirement — the ATCUD code and the fiscal QR code — is mandatory on every Portuguese invoice and is not implemented. Read this page before invoicing in Portugal.

ATCUD and the QR code are missing

Since 2021, Portaria n.º 195/2020 requires every invoice to carry an ATCUD (a validation code obtained by pre-registering a numbering series with the AT, concatenated with the document's sequence number) and a fiscal QR code — art. 4.º n.º 1: "O ATCUD, com o formato «ATCUD:CodigodeValidação-NumeroSequencial», deve constar obrigatoriamente em todas as faturas e outros documentos fiscalmente relevantes."

This app does not compute either. The only occurrence of ATCUD in the codebase is a hardcoded placeholder in reporting/providers/pt-declaration-provider.ts:

// "deve ser preenchido com «0» (zero) até à sua regulamentação" (field 1.6.2) — quoted verbatim
// from the manual; this bridge does not compute a real ATCUD.
'doc:ATCUD': '0',

That placeholder is the AT's own documented value for "not yet regulated for this sender" — this app uses it because it has no real series registration or ATCUD generator, not because Portuguese law makes ATCUD optional. An invoice issued today through this app for a Portuguese company is missing a legally required element.

Two further pieces of the same regime are also not implemented: the certified-software status required once turnover exceeds €50,000 and organized accounting applies (Decreto-Lei n.º 28/2019 art. 4.º) — this app is not AT-certified — and the chained RSA signature every certified program must print as a 4-character hash on each document, each one cryptographically tied to the previous document in its series (Portaria n.º 363/2010 art. 6.º).

No transmission channel, no B2G

• transports/channel-policy/data/pt.json exists and deliberately declares no fact (2026-09-13). That is a sourced conclusion, not a gap: Decreto-Lei n.º 28/2019 art. 12.º n.º 1 makes electronic transmission itself optional and consent-based — "As faturas e demais documentos fiscalmente relevantes podem, mediante aceitação pelo destinatário, ser emitidos por via eletrónica" — the verb being podem (may), not devem (must). Portuguese law names no platform, unlike France's PDP or Italy's SdI, so nothing here constrains which channel a Portuguese seller uses. The file's own notes carry the retrieval and the quotations.
• What Portuguese law does impose at this level is a certified invoicing software obligation above a turnover threshold (same decree, art. 4.º) — a fact about the software, not about the transport, and one this app does not satisfy today (it is not AT-certified). The two must not be conflated.
• No b2g-routing file exists either — selling to a Portuguese government client (which requires CIUS-PT) is not implemented. This app's own country-policy notes record why: CIUS-PT could not be vendored, the third-party portals that carry it vary, and no Peppol coverage was found for Portugal on the European Commission's own eInvoicing factsheet.
• No Portugal-specific invoice format exists in this app either — a Portuguese invoice is built with the same generic engine every unmodeled country uses, not a CIUS-PT profile.

Monthly reporting is built but unproven

A provider (reporting/providers/pt-declaration-provider.ts) implements the AT's real-time e-invoice-communication webservice contract — one of three ways Decreto-Lei n.º 198/2012 art. 3.º lets a business meet its monthly reporting obligation (the other two, a SAF-T (PT) file or direct portal entry, are not built here). It has never been run against the real AT service: this checkout holds no AT "subutilizador" identifier or public key, and because it feeds the same un-computed ATCUD placeholder described above, even a successful call would be reporting invoices that are not themselves fully compliant.

Tax

VAT, three continental rates, all sourced to the Código do IVA (CIVA) as served by the AT, read directly 2026-09-04:

These are the rates for mainland Portugal only. Madeira and the Azores set their own regional rates under a delegation in CIVA art. 18.º n.º 3 (a 2026-09-04 check of the EU's TEDB found regional standard rates of 22% for Madeira and 16% for the Azores) — neither region's own reduced rates are modeled here.

Identifiers

• NIF / NIPC, required on the seller unconditionally (CIVA art. 36.º n.º 5, a)) and required on the buyer only when the buyer is itself VAT-registered, or on request otherwise (n.º 16 of the same article). No digit-count pattern is declared — the founding decree for the NIF format (Decreto-Lei n.º 463/79) could not be reached in primary text.
• VAT number, not required below the €15,000/year exemption threshold (CIVA art. 53.º n.º 1). Its usual equivalence to the NIF/NIPC prefixed "PT" is a common convention, not one this catalog found stated in the law itself.

Correcting or cancelling an invoice

Only 4 of the 11 correction routes are sourced to Portuguese law: a credit note and a corrective invoice are allowed, a debit note is required for the cases it covers. A ledger-only annotation is also allowed. The other seven routes, including cancel-and-replace, are unverified — and because CANCEL_AND_REPLACE has no confirmed status, cancelling an issued invoice locally is not implementable in this app for Portugal today; an attempt is refused by name.

Sources

backend/src/modules/documents/country-policy/data/pt.json, country-identifiers/data/pt.json, correction-routes/data/pt.json, correction-routes/cancel-policy.ts, tax/tax-systems/data/pt.json, vat-rates/data/pt.json, reporting/data/pt.json, plus reporting/providers/pt-declaration-provider.ts for the ATCUD placeholder quoted above, and archive/retention/data/pt.json for the ten-year retention (CIVA art. 52.º n.º 1). transports/channel-policy/data/pt.json exists but declares no fact, for the sourced reason given above. No b2g-routing/data/pt.json file exists.