SAF-T and reporting to the AT: what changed this year in Portugal

In 2026, the changes affecting invoicing in Portugal were mainly about deadlines: the 2026 State Budget Law (Law No. 73-A/2025 of 30 December) postponed the submission of accounting SAF-T once more, extended the acceptance of PDF invoices to the end of the year and removed the requirement to value inventories in the annual report. We summarise what is in force and what it requires of the ERP configuration.

What stays the same

Invoice reporting. Article 3 of Decree-Law No. 198/2012 of 24 August requires invoice details to be reported to the AT. For documents issued since 1 January 2023, the deadline is the 5th of the following month. The AT accepts three methods:

• real-time transmission via web service;
• submission of the invoicing SAF-T (PT) file on the Portal das Finanças or via command line;
• direct entry on the Portal das Finanças.

ATCUD. The unique document code comes from Article 7(3) of Decree-Law No. 28/2019 of 15 February and is regulated by Ministerial Order (Portaria) No. 195/2020 of 13 August. It must appear on all invoices and tax-relevant documents, with no exception by type: receipts, transport documents and purchase orders included. It does not depend on the issuer's turnover or VAT regime and, on a document with several pages, it appears on every page.

The ATCUD combines the series validation code, a hyphen and the document's sequential number. Because the validation code is assigned by the AT when the series is reported, no series can be used before it has been reported. The QR code is only mandatory on documents issued by certified invoicing software.

What changed in 2026

Article 95 of Law No. 73-A/2025 covers three obligations:

• Accounting SAF-T: submission of the file under Ministerial Order (Portaria) No. 31/2019 of 24 January only applies to periods from 2027 onwards, to be submitted in 2028 or later.
• PDF invoices: until 31 December 2026 they continue to be accepted and treated as electronic invoices for all tax purposes.
• Inventories: in the report required by Article 3-A of Decree-Law No. 198/2012, all taxpayers are exempt from valuation for periods beginning in 2025 or later, and those not required to keep permanent inventory from the 2026 period onwards.

Update of 21 October 2026

The Ordem dos Contabilistas Certificados reported on 9 October that the 2027 State Budget proposal postpones accounting SAF-T again and keeps the acceptance of PDF invoices until the end of 2027. It is a proposal: until the law is approved and published, the deadlines in force are those of Law No. 73-A/2025.

What to check in Sage X3

• Document series: each new series, or each numbering restart, must be reported to the AT before the first document. It is advisable to review series at the start of each year and whenever a company or document type is created.
• Document types: transport documents, receipts and other documents outside sales invoicing also carry an ATCUD.
• Reporting method: confirm whether the company reports via web service or by monthly file and, in the latter case, who ensures it is sent by the 5th.
• Inventory: stop sending the valuation when the company is exempt, without changing the reporting of quantities.
• PDF invoices: identify the customers and suppliers that exchange invoices only as PDF, because acceptance has an end date.

These points are handled by Sage’s Portuguese localisation in Sage X3. When a legal change requires configuration changes, we make them for our clients and publish the corresponding note in Resources.