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Portugal

Policy module: src/events/compliance/policies/pt.py (PortugalPolicy, using FiscalizedInvoicingMixin).

Issue: #1060

Status

Restricted: attendee invoicing blocked for organizers established in Portugal.

A Portuguese taxable person that issues invoices with software must use only software certified in advance by the Autoridade Tributária e Aduaneira (AT). Revel is not AT-certified, and its PDFs lack the mandatory ATCUD and AT QR code.

What Revel does

  • Attendee invoicing cannot be enabled. Switching to HYBRID or AUTO is refused (HTTP 422) for organizations whose resolved country is Portugal, with a translated explanation, naming Portugal, that invoices must go through certified invoicing software.
  • Generation is skipped (invoice generation, issuing an existing draft, including drafts created before the gate, and credit notes) for sales by organizers established in Portugal. A foreign organizer's event held in Portugal is not affected.
  • Existing settings: organizations in Portugal that had HYBRID or AUTO were switched to NONE by the data migration 0128_disable_blocked_attendee_invoicing. Existing invoices were not touched. No notification was sent automatically, so affected organizers should be informed out of band.
  • Online and offline payments are not restricted.
  • The common ticket content applies. It covers the ticket details DL 23/2014 art. 8 asks for: the promoter's identity and tax ID (when the organization's VAT ID is set), the price, and a sequential number, alongside the event, venue, date and seat category.
  • Art. 8 reaches events held in Portugal, whoever organizes them. The ticket content follows the show's location, not the organizer's establishment; since the common ticket content is printed on every ticket, a foreign organizer's event in Portugal is covered too. (The invoicing gate above is different: it keys on the organizer being established in Portugal.)
  • Per-organization numbering meets art. 8(1)(e). The consolidated DL 23/2014 asks only for "numeração sequencial". It says nothing about numbering per show, venue or series, and nothing about communicating number ranges to IGAC. Revel's gap-free per-organization counter satisfies that. The predecessor, DL 315/95 art. 30(2) (repealed), tied unnumbered seating to the venue's capacity, which implied one counter per show; DL 23/2014 dropped that link and moved the capacity rule to art. 8(2). A per-event number is not built unless a Portuguese lawyer or IGAC says otherwise (#1088).
  • Inspection (art. 8(5)). When access is checked by one of the means art. 8(5) lists (such as barcode or card readers) or without a ticket, the promoter must keep the art. 8(1) details available for inspection. Revel's exports cover most of them: the attendee export (attendee, tier, seat, payment) and the revenue report, whose Transactions sheet carries each ticket's sequential number next to the transaction amounts (#1090). Neither carries the promoter's NIF, which organizers without a VAT ID set must take from their own records.
  • No data transmission. The ticket-data transmission under DL 125/2003 art. 5(3) applies to cinema tickets and sessions only, so it does not apply to the events Revel sells. The one exception is DL 125/2003 art. 3-B (added by DL 65/2026, in force since 10 March 2026): promoters at public-sector venues must send IGAC and INR data on the free companion tickets they issue. Like the rest of DL 65/2026's companion-ticket rules, this falls outside Revel's typical customers.
  • Gaps: age classification is not supported (#1108): neither the classification shown on the event's website (art. 8(3)), nor the "aguarda classificação etária" notice on tickets sold before a classification is assigned (art. 6(4)). The point-of-sale information list in art. 6(1), age classification included, binds only sales platforms run by companies established in Portugal, so it does not bind Revel directly. Organizers without a VAT ID get no NIF line (#1078).
  • DL 28/2019: certified software is mandatory if any one condition is met, including using invoicing software (art. 4(1)); third-party invoice preparation leaves the organizer liable (art. 5(1)); online tickets do not qualify for the ticket carve-out (art. 4(6)); ATCUD and QR code on every fiscally relevant document (art. 7(3)). AT consolidated text, DR, AT FAQ
  • CIVA arts. 29, 36 and 40: invoice obligation, deadlines and content; a ticket can replace the invoice but is then a fiscal document. art. 29, art. 36, art. 40
  • Portaria 195/2020 (ATCUD and QR), Portaria 363/2010 (certification), Despacho 8632/2014 (technical requirements): Portaria 195/2020, Portaria 363/2010, Despacho 8632/2014
  • e-Fatura reporting (DL 198/2012): AT FAQ, DL 198/2012
  • DL 23/2014 art. 8: ticket content for artistic shows, including "numeração sequencial" (art. 8(1)(e)), the capacity rule (art. 8(2)) and the inspection duty (art. 8(5)); promoter registration with IGAC. Compared with DL 315/95 art. 30(2) (repealed), which tied numbering to venue capacity. PGDL consolidated text, DR 2014, IGAC
  • DL 65/2026: companion tickets (public-sector venues only) and WCAG 2.1 AA for ticketing platforms. DR, Government communiqué
  • AT list of certified programs

Open questions

  • Whether any de-minimis exception applies to small associations (the CIVA art. 53 threshold is unverified).
  • Non-resident organizers VAT-registered in Portugal may also be covered, since the trigger is a PT VAT obligation, not only a seat in Portugal. Revel currently blocks only organizers established in Portugal.
  • Whether a foreign producer without a PT tax number can file for certification; the exact QR spec and test procedure.

Later layers

  • A per-order export so organizers can key or import invoices into their own certified software, and optionally an integration with a certified invoicing provider chosen by the organizer.
  • Only if the market justifies it: Revel becoming an AT-certified producer (signed hash chains, ATCUD and QR, SAF-T export, e-Fatura).

See #1060.