SAF-T in Portugal, explained
Portugal was the first country to adopt the OECD SAF-T standard (2008-2009). The billing file (SAF-T PT) is submitted every month to the Tax and Customs Authority (AT). A separate accounting file is also part of the regime, but its start date has been postponed more than once, so check the current date with the AT.
General information only, not tax advice. Rules change, so check the official sources at the bottom of this page before you act.
The mandate
SAF-T PT — Standard Audit File for Tax Purposes
Who must file
All taxpayers using accounting or invoicing software in Portugal.
How it works
Certified invoicing software generates the SAF-T PT billing file (XML) → submitted every month to the AT portal → AT cross-checks it against e-Fatura and the VAT return.
Key dates for Portugal
- 2008-2009SAF-T PT introduced
- 2013Monthly submission of the billing file introduced
- Jun 2022Billing file reporting applies to residents and non-residents
- To be confirmedAnnual accounting file: start date postponed again. Confirm the current date with the AT
What the file contains
Portugal requires two distinct SAF-T file types: the billing file (SAF-T Facturcao) covers all invoicing documents and must be submitted monthly by the 5th of the following month. The accounting file (SAF-T Contabilidade) covers the full general ledger and is submitted annually. Both files must be generated from certified invoicing/accounting software registered with AT.
What your ERP has to deliver
ERP and accounting systems must be AT-certified and capable of generating SAF-T PT XML in the exact schema version mandated. The software certification process itself is non-trivial — the invoicing software must produce sequential, tamper-evident invoice numbers with hash signatures. Systems must support both billing and accounting SAF-T exports with different scopes and periodicities.
The data flow, step by step
Practical insights
- Portugal's SAF-T is the oldest and most mature implementation globally. The AT has built extensive automated cross-checking between SAF-T data, e-Fatura (consumer invoice portal), and VAT returns. Discrepancies are flagged automatically.
- The software certification requirement is unique to Portugal. Companies cannot simply 'add SAF-T export' to any software — the invoicing software itself must be certified by AT, including hash-chain invoice numbering. This affects vendor selection significantly.
- The monthly billing SAF-T and annual accounting SAF-T serve different audit purposes. The billing file enables real-time VAT monitoring; the accounting file enables comprehensive tax audits. Companies must manage both workflows.
- Portugal's QR code requirement on invoices links directly to SAF-T data. The QR code contains a hash that AT can verify against the SAF-T submission, creating a closed-loop validation system.
Common pitfalls
- Using non-certified invoicing software — AT can reject SAF-T submissions and impose penalties if the generating software is not in the certified registry.
- Missing the monthly 5th-day deadline for billing SAF-T submission, which triggers automatic penalties.
- Not reconciling SAF-T billing data with VAT return figures before submission — AT's automated cross-checks will flag discrepancies.