FREQUENTLYASKED QUESTIONS
Welcome to our Electronic Invoicing Frequently Asked Questions (FAQ) section. We are here to simplify your use of our platform, making electronic invoicing a simple and hassle-free experience for your company..
What is an e-invoice?
An e-invoice is an invoice that has been issued, transmitted and received in a structured electronic format that enables it to be processed automatically and electronically, as defined in paragraph 1 of Article 2 of Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014 on electronic invoicing in public procurement.
Who is obliged to issue e-invoices?
Public Administration suppliers, as co-contractors, are obliged to issue e-invoices when executing public contracts, as established in Part III of the CCP, article 299-B.
Am I obliged to submit the original PDF of my invoices?
Although the presence of the original PDF of the invoice is not mandatory according to the CIUS-PT standard, a large number of public bodies impose this obligation to facilitate the validation and digital archiving of invoices. To avoid delays and payment obstacles, we recommend that the original PDF always accompanies the electronic invoice.
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An electronic invoice is an invoice that has been issued, transmitted, and received in a structured electronic format that allows for its automatic and electronic processing, as described in paragraph number 1, article 2, of Directive 2014/55/EU, of the European Parliament and of the Council, dated of 16 April, 2014, on electronic invoicing in public procurement.
Electronic invoicing requires that the data be created with the correct structure (defined by a standard European model) and, after that, be sent from the seller's system to the buyer's system. In this way, the invoice can be automatically imported into the public entity's system.
An electronic invoice typically uses an electronic data interchange (EDI), in which a structured data file is transmitted for subsequent automated processing.
According to Ordinance No. 289/2019, of 5 September, the proposed semantic data model for the Portuguese Standard (CIUS-PT) as well as the list of syntaxes that electronic invoicing documents must comply with, are available in the Standards on Electronic Invoice.
The model complies with the European Standard EN 16931-2017, of June 28th, 2017 from the European Committee for Standardization, made available through the Portuguese Institute of Quality (Instituto Português da Qualidade).
All public entities (as public procurement authorities) referred to in Article 3 of the Public Procurement Code (Código dos Contratos Públicos [CCP]) are required to receive and process electronic invoices.
The
following are included in the concept of public procurement authority:
- The contracting entities referred to in number 1 of Article 2 of the CCP;
- The entities covered by number 2 of Article 2 of the CCP, when contracts entered into by them are qualified by the parties as administrative contracts, or subject to a substantive public law regime;
- Any entities that enter into contracts in the exercise of materially administrative functions.
Examples of public procurement authorities: the General and Regional Directorates, the Presidency of the Republic, Public Institutes, Autonomous Regions, Local Authorities, Independent Administrative Entities, Bank of Portugal, among others.
Yes, under the scope of Art. 299.ºB of the CCP (Public Procurement Code - Código dos Contratos Públicos [CCP]), the only exceptions provided are the simplified direct award procedure (128/3 CCP) and secret contracts or contracts accompanied by special security measures (Art. 299.º-B CCP).
Yes.
Yes, unless it concerns a simplified direct agreement or contracts accompanied by special security measures.
Yes, if the legal relationship in question is subject to the mandate as stipulated in the CCP.
Suppliers to the Public Administration (PA), when acting as co-contractors, are required to issue electronic invoices within the framework of the execution of the public contracts, as established in Part III of the CCP, article 299-B.
Co-contractors can be either private entities or public entities, as long as they act as suppliers to the PA in the execution of public contracts. Co-Contractors under excluded contracting, though exempt from the rules for the formation of contracts established in Part II of the CCP, still maintain the obligations of Part III, according to article 5-B.
The exceptions provided for the non-requirement of an electronic invoice in public contracts are due to purchases made under:
- Simplified direct award procedures, as amended by Law No. 30/2021;
- Contracts declared secret or accompanied by special security measures (paragraph 2 of article 299-B of the CCP).
Yes, in cases where the invoices result from direct award procedure ("general regime"). In cases where the invoices result from a simplified direct award procedure, under paragraph 3 of article 128 of the CCP, the issuance, receipt, and processing of invoices in electronic format is not mandatory.
Large companies are required to issue electronic invoices, in accordance with the European standard, since 1st January 2021, as per paragraph 3 of article 9 of Decree-Law No. 111-B/2017, of 31 August, in the current wording. For the remaining companies and public entities, as contracting parties, the deadline for issuing electronic invoices has been extended to 1st January 2025, according to article 305 of law 82/2023, of 29 December.
When an electronic data interchange system (EDI) is used, as per paragraph c), number 2 of Article 12 of Decree-Law No. 28/2019, of 15 February, in its current wording, the obligation to sign electronic documents depends on the electronic data transfer channel.
In cases where the documents are sent via AS2 protocol, signing the documents is optional because it is already used in the transport protocol (S/MIME and X.509 certificates).
Other documents sent by PA suppliers to public entities must use a qualified digital signature or qualified electronic seal, as per paragraphs a) or b) of the aforementioned article.
As of the date of this article, you may use simplified PDF invoices as electronic invoices, for all fiscally relevant purposes, until the end of 2025, in accordance with Article 114 of Law 45-A/2024, of 31 December.
Once the acceptance period for simplified PDF invoices ends, you will have to take into account the premises of Section II of Decree-Law No. 28/2019, of 15 February, which defines the conditions for the issuance of invoices electronically.
Qualified electronic signature – much more than a simple digital signature, a qualified signature is an exclusive and non-transferrable identification generated from a secure device (QSCD – Qualified Signature Creation Devices). It is a cryptographic system, which confirms the authorship of the document, identifying the company responsible for its issuance and guarantees the integrity of the data. The holder of the document has access to a private key which allows them to claim authorship of it.
Qualified electronic seal – this is a digital and secure version of the company's stamp. Unlike a qualified electronic signature, this element only allows identifying an organization (legal person) and not an individual document holder. This product allows automating the signing process without human intervention.
The ilink portal offers the following methods for importing documents:
- Manual Import - allows for a manual digitization of the document's information;
- Automatic Import - allows the automatic importation of a pre-generated electronic invoice XML file from the ERP;
- OCR Import - allows for the optical recognition of the information in the printed document;
- SAF-T Import - allows the automatic reading of the invoices present in the SAF-T file.
After registering on the platform, simply request a connection with the receiving entity through the 'Connections' menu. Then, simply create a document by one of the existing methods (manual, automatic, OCR, SAF-T) and use the 'Send' button, or through automatic integration of the invoicing software in use. It should be noted that depending on the receiver of the document, it may be necessary to purchase a service package to send the document.
There are no document sending costs to contracting entities that cover the costs of the sent documents. However, for sending to other recipients, including customers outside of the ilink network, it will always be necessary to purchase a transaction package.
You can consult the existing transaction packages at the top of the page, under the 'Services' option. If you require a proposal tailored to your needs, please use our simulator or the Click to Call banner to be contacted.
Transactions are valid for 1 year. This information can be checked on the service purchase page.
The consumption of transactions on ilink will be made based on the size of the document, where one transaction will be charged for each 1MB of document size sent/received.
You can check the statement of all transaction consumptions in the operations area.
While the presence of the original invoice PDF is not mandatory under the CIUS-PT standard, a large number of public entities require this document in order to facilitate the validation and digital archiving of the invoices. To avoid delays and issues with payments, we always recommend that the original PDF should always be sent with the electronic invoice.
For a better organization of the purchasing and selling process, 4 simplified statuses of documents were established.
- To be sent (created but not yet sent to the receiver);
- Sent (sent to the receiver);
- Accepted (received and checked by the receiver);
- Rejected (received and returned by the receiver due to a discrepancy).
If the document received contains incorrect fiscal relevance information, such as the recipient of the document or the value of the items, you should use the option to 'Return the document'. If the invoice is correct in fiscal terms but is missing additional information (such as the commitment number or the order number), you should use the 'Regularize' action. This allows the supplier to correct the missing information and resend the document.
In both situations, it will be necessary to enter a reason for rejecting the document in question.
All documents can be exported from the platform in Excel and ZIP formats. This operation is available on all document tables within the platform. Simply apply the desired filters in the search and click on either of these two options, and you will receive a link with the requested information via email.
According to articles 6 and 12 of DL 28/2019, submission through the EDI system, the qualified electronic signature or seal certificate, ensure the authenticity and integrity of the electronic invoice. This means that the signature or seal is mandatory for B2C/B2B transactions (such as sending PDF via email), while it becomes optional for EDI communications (sending XML CIUS-PT to public entities).
Besides being a legal requirement in the cases identified, the electronic signature is also a way to increase the security of the document by ensuring its integrity.
Currently, it is only possible to integrate with the Global Trusted Sign (GTS) provider.
No. The certification of the invoice aims to unequivocally identify the issuing entity of the invoice, i.e., the contractual party, so the signature or seal used on the invoice must be issued in the name of the entity that actually issues the invoice. The National Security Office has already clarified this matter in its Communication 01/2021.
An invoice not signed by its issuer and signed by a third party should be rejected.
The electronic seal must be issued and setup in the platform and the signature authentication process has to be carried out every 60 days. This allows for the automation of the signing process without human intervention.
Yes. We do not charge any connection fees for external software, and we are always open to new partnerships and integrations. Consult the technical documentation to learn about the entire integration and implementation process.
This information is available on our integrations page and in our integrations documentation.
Yes. ilink is interconnected with all operators in the Portuguese market.
This process can be initiated from the connections area, where you can request an external connection with a client outside the network. If the client you are looking for is not on the previous list, please contact our support service.
Yes, but it will only be possible to extract the generated XML after the document has been sent to the end customer.
The ESPAP (Entidade de Serviços Partilhados da Administração Pública, I. P.), is a public institute under a special regime, for the purposes of designing and developing solutions, applications, platforms, projects and carrying out activities leading to or necessary for the provision of shared services and public purchases. eSPap coordinates the implementation of Electronic Invoicing in Public Administration (FE-AP). With Decree-Law No. 123/2018, of December 28, eSPap was given the authority to issue technical and functional requirements that support the implementation of electronic invoicing, develop support instruments for covered entities and provide the solution for reception and electronic invoice processing.
The Electronic Invoice Portal in Public Administration – FE-AP – is the state's Gateway for receiving and processing electronic invoices. Any public entity can join the FE-AP service to receive electronic invoices, and this portal is fully integrated with the ilink platform.
Sending invoices to the FE-AP operator is done in the same way as with other operators; however, it is necessary to complete the FE-AP supplier onboarding process before starting.
At ilink, we support our customers through this process, ensuring they are operationally onboarded and ready to send documents to the intended FE-AP recipients.
For more information, please consult our guide.
Yes, we are increasingly connected to service providers within the European space. However, any interoperability with companies outside Portugal must be validated during the project implementation phase with our commercial team. This is because each European market has different rules for electronic invoicing.
Yes. You may buy a PDF Transaction package, which is used solely to send invoices via email, or you can request a quote by using our click to call service and we will contact you.
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