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    Beginning in January 2023, B2G electronic invoicing will be mandatory for all companies in the country.

    Portugal is moving towards electronic invoicing, but not as fast as expected due to the pandemic. First, in 2021 the country introduced electronic invoicing in the B2G (Business to Government) environment for large companies. The following year they passed a measure requiring the use of QR codes on all electronic invoices.

    Currently and after grace periods aimed at the recovery of the business activity, everything suggests that 2023 will be a relevant year. The most important changes related with electronic invoicing in the country are provided below:

    Mandatory requirement for all companies to use B2G invoicing

    Portugal, like other countries, has been gradually implementing the mandatory requirement for using B2G electronic invoicing.

    In January 2021, a measure was passed requiring the use of electronic invoicing for large companies doing business with public administrations; in other words, companies with more than 250 employees or with an annual turnover exceeding 50 million euro.

    On January 1st 2023, the use of B2G electronic invoicing will also be mandatory for the small and medium enterprises of the country.

    With this step, the totality of companies operating in the B2G electronic invoicing environment will be required to implement electronic invoicing.

    Introduction to the ATCUD Code

    The ATCUD code must be included on all types of invoices and tax documents. This is a unique identification number for documents comprised of 8 digits. It is comprised of two parts separated by a dash (-):

    •     Service validation code (assigned by the Portuguese tax authority).
    •     Unique document code within the issued batch numbers (generated by the software of the taxpayers themselves).

    Companies must submit a request to the tax authority web service (Autoridade Tributária e Aduaneira) to obtain a batch of numbers that will be subsequently used on the invoices.

    Qualified electronic signature for e-invoices in PDF

    Beginning in January, Portugal will also implement the mandatory requirement to include the Qualified Electronic Signature on electronic invoices in PDF format. This signature, which has the same legal standing as a hand written signature, must be included in the PDFs and on any non-EDI invoice.

    The requirement will be applied to any type of transaction within the B2G, B2B (Business to Business) and B2C (Business to Client) sectors.

    Bavel, which is Voxel’s electronic invoicing platform, is ready to meet the B2G requirements in Portugal. If you wish to stay abreast of any new developments related with the electronic invoice regulation, please subscribe to our newsletter.