Portugal B2G E-invoicing

From 18 April 2020, Portuguese authorities have to accept electronic invoices when a government vendor wishes to submit, following Directive 2014/55/ EU of the European Parliament. As a second step, electronic invoicing to public authorities in Portugal is gradually becoming mandatory for all vendors. This regulation includes invoicing to all public administrations (national, local, and regional).

What is eSPap?

Entidade de Serviços Partilhados da Administração Pública I.P.” or “eSPap” is the government authority responsible for setup and maintenance of the e-invoicing system. FE-AP is the e-invoicing portal developed by eSPap. All State and public authorities with direct management service must use the FE-AP solution to receive e-invoices. However, other public entities such as Autonomous Regions, independent administrative bodies, Bank of Portugal, and public foundations are free to use any portal other than FE-AP. Therefore, vendors are encouraged to consult the entities they sell goods or supply services to learn which portal should receive the e-invoices.

Who is eligible to use E-invoice in Portugal?

Today, any company eager to take advantage of electronic invoicing can start using it voluntarily. All companies will be required to join the e-invoicing system in Portugal in the near future. First, large enterprises will be obliged to issue e-invoices for transactions with government entities as of 1 January 2021. Then, from 1 July 2021, medium and small enterprises and from 1 January 2022, micro enterprises and public entities will be obliged to comply with the regulation. eSPap classifies the enterprises under obligation according to their employee number, turnover and balance sheet volume:


Large enterprise: employs over 250 people or has an annual turnover of more than 50 million euros or a total annual balance sheet of more than 43 million euros.

Medium-sized enterprise: employs less than 250 people and has an annual turnover of 50 million euros or less or a total annual balance sheet of 43 million euros or less;

Small enterprise: employs less than 50 people and has an annual turnover or total annual balance of 10 million euros or less;

Microenterprise: employs less than 10 people and has an annual turnover or annual balance sheet of 2 million euros or less;


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