How long do you keep invoices in Portugal, and can you go paperless?

Every few months someone posts in an expat group that you only need to keep invoices for 4 years in Portugal. The thread fills up with people tagging their friends. Most of them believe it.

The 4-year figure is real. It is just not the retention period.

It is the caducidade: the window during which the AT can reassess a tax return. Article 45 of the LGT (Lei Geral Tributaria) gives the AT 4 years to go back and correct an assessment. Beyond that, the return is generally closed. Four years, and you're clear.

The document retention requirement is different, longer, and in a different law entirely.

The actual rule: 10 years

Article 52 of the CIVA (the VAT code) requires you to keep invoices, receipts, payment proof, and all supporting documents for 10 years. The clock starts at the end of the civil year of the transaction, not the document date.

A Stripe invoice from March 2026 needs to be kept until 31 December 2036.

The same 10-year obligation appears in Article 123 of the CIRC (the corporate income tax code) and in Article 40 of the Codigo Comercial. It is not a quirk of one law. It runs across the whole tax and commercial framework.

Why longer than the caducidade? Because tax disputes, fraud investigations, and commercial claims can extend the AT's reach beyond the standard 4-year window. An undisclosed offshore income source discovered in year 5 can push the caducidade out to 8 years. Document falsification can push it further. Keeping documents for 10 years gives you a buffer regardless of what gets discovered later.

The 4-year figure is accurate for a narrow purpose: knowing when a standard return is probably closed to routine reassessment. It is wrong as a guide for when to bin receipts.

Going paperless

The good news is that Portugal does not require you to keep paper. Since Decreto-Lei 28/2019, you can scan paper documents, keep only the digital archive, and destroy the originals.

There is no value threshold. A café receipt for a euro and a half and a car invoice for fifty thousand euros are treated identically under the law. You do not need to keep originals above a certain amount. The rule is value-blind. The framework also covers both documents you issue and documents you receive: invoices, transport documents, receipts, and anything else with fiscal relevance under Art. 23 of DL 28/2019. Once digitised into a compliant archive, the digital copy carries the same evidentiary weight (valor probatório) as the paper original.

One practical constraint on the received side: for supplier invoices where you deducted input VAT, destroy the paper only after you have exercised the VAT deduction right. File the quarterly IVA return that includes the deduction, then scan and discard the paper. The digital copy is what you keep for the 10-year period.

The archive is the gate, not the document

Here is where this gets slightly more specific than it might first appear, and where "my phone camera works fine" runs into trouble.

DL 28/2019 Art. 6 and Art. 19-23 set out what a compliant digital archive must do: guarantee authenticity of origin, guarantee integrity of content, remain legible for the full retention period, include controls that prevent alteration, provide a reliable audit trail, and reproduce each document perfectly without information loss. The AT does not specify a particular technology or software product. What it does specify is that the archive must demonstrably satisfy those conditions.

A certified document management system, a proper accounting or expense tool, or a cloud archive with version history and tamper-evidence satisfies this. A folder of photos on your phone does not, because ad-hoc phone storage has no integrity controls, no audit trail, and no mechanism to prevent replacing the original photo with a different one. The photo itself might be a perfect image. The storage context fails the legal test.

This matters most for expenses you intend to claim. If you are going to tell the AT "I documented this expense, here is the proof," that proof needs to live in an environment the AT can regard as reliable. A reputable cloud provider with automatic version history is a reasonable baseline. An expense management tool that records the upload event and locks the file is better. The value of the document is irrelevant to this requirement. A two-euro parking receipt and a five-thousand-euro equipment invoice face the same archive standard.

Travel receipts as an employee

This is worth a short detour because the dynamic shifts when you are an employee rather than the business.

If you photograph a travel receipt before discarding the paper, the receipt is a received document for your employer, not for you. The employer holds the archive obligation. The photograph needs to land in the employer's DL 28/2019-compliant expense system, not on your personal phone. Whether the employer reimburses the expense also depends on company policy and on the receipt being a valid supporting document in the first place.

The scenario where this breaks: you photograph the receipt, send it in a WhatsApp message, and bin the paper. The WhatsApp message fails the archive test. If the employer later cannot produce compliant documentation, the expense can be challenged, and you, as the employee who discarded the original, created the gap.

This is exactly how Sweden and Norway have handled it for years. I covered Sweden's 2024 rule change and Norway's earlier approach in an earlier post. What that post did not mention is that Portugal has allowed the same thing since 2019, under a framework that predates Sweden's move. The mechanics differ slightly but the outcome is identical: no paper box required, as long as your archive qualifies.

Why the rules differ across the EU

If you moved here from another EU country, you may be wondering why Portugal says 10 years when your previous home country said something different. Sweden, for example, is 7 years. You are not misremembering. Every EU country has a version of these rules, but the number changes depending on where you are.

The reason is that this is EU law, but deliberately incomplete EU law.

The legal foundation for invoice storage across all EU member states is the EU VAT Directive (2006/112/EC), specifically Articles 244 to 247. That is why every EU country has the same basic shape: store your invoices, you can go paperless, cross-border storage is permitted with some conditions. The framework is harmonised at the EU level.

But Article 247 of the Directive explicitly hands the retention period and format details to each member state. The EU sets the shape of the obligation; each country fills in the numbers. Portugal chose 10 years, anchored in Article 52 CIVA. Sweden chose 7 years under its Bokforingslagen (accounting law), and updated its paperless rules in July 2024 to allow scan-and-bin in the same way Portugal has since 2019.

There are other dials that member states can set independently: whether you need to notify the tax authority if records are stored in another country, whether storage within the territory is required for certain document types, what archive integrity standards apply. Portugal's rule here is that records can be stored anywhere in the EU, but outside the EU the AT needs guaranteed online access.

The practical takeaway is simple: do not assume your previous country's rules carry over. The EU harmonises the obligation to keep records and the basic right to go paperless. It does not harmonise the specifics. In Portugal, those specifics are: 10 years, EU-stored by default, paperless allowed under DL 28/2019 as long as the archive qualifies.

Who this applies to

DL 28/2019 is a business framework. It applies to sujeitos passivos: sole traders on the simplified regime, sole traders on organized accounting, and companies including Ldas. All of them have the same archive obligation, and all of them can take advantage of the scan-and-bin rule when the archive conditions are met.

Private individuals have it easier. Their deductible personal receipts (health, education, and similar) are already captured in e-Fatura by the merchant at the point of issue. Private individuals have no paper-keeping obligation of their own for those expenses. The system records the transaction; they just need to confirm it.

For everyone running a business, though, the obligation sits with you.

What happens if you cannot produce proof

This comes up more often than people expect. A client relationship ends, a hard drive dies, a folder structure that made sense three years ago no longer does. The AT sends a request. You cannot find the invoice.

For expenses claimed under the simplified regime, the consequence is specific. Article 31 n.13 of the CIRS requires you to prove at least 15% of your gross income in documented expenses. If your documented total falls short, the shortfall is added to your taxable income before the coefficient runs. It is not a penalty in the criminal sense. It is an adjustment that increases what you owe.

On top of the tax adjustment, the AT can apply coimas (administrative fines) under the RGIT and juros compensatórios (compensatory interest) on the underpaid amount. The interest rate is set annually and is not trivial.

The practical implication is that "I lost the invoice" does not work as a defence. The obligation to keep records sits with you. If you cannot produce documentation the AT requests, the expense is disallowed as if it never existed.

This is not theoretical. Portuguese audits of sole traders are not common, but they happen. And audits disproportionately target taxpayers where the expense-to-income ratio looks unusual, where VAT deductions seem high relative to sector norms, or where there is a mismatch between declared income and apparent assets.

Foreign invoices and the verification gap

Portuguese supplier invoices have an electronic trail. When a Portuguese supplier issues you an invoice through AT-certified software, the transaction flows through the e-fatura system. AT has an independent record.

A Stripe invoice does not. Neither does an AWS bill, a Google Workspace subscription, or any invoice from a supplier outside the Portuguese tax system.

When you claim foreign expenses toward the 15% documented expense requirement (either by registering them manually on the e-fatura portal or declaring them directly in Anexo B Quadro 17 of your IRS Modelo 3), you are the only source. There is no electronic chain the AT can independently verify. Your invoice and payment confirmation are the entire record.

That makes the 10-year retention rule more consequential for foreign expenses than for domestic ones. Bin a Portuguese supplier invoice and there is a reasonable chance the transaction still shows up in the e-fatura trail. Bin a foreign supplier invoice and it is gone.

Keep originals, or scanned copies per DL 28/2019. Keep the bank statement or payment confirmation showing the transaction. If the invoice is in a foreign currency, keep the conversion documentation.

The 15% expense rule fact page has the full mechanics of what counts and how the calculation works.

What certified invoicing software does for you

If you use AT-certified invoicing software to issue your own invoices and receipts (faturas, faturas-recibo, and related document types), your issued documents are already stored. Certified software communicates invoice data to AT as documents are issued. You are not responsible for separately archiving what you sent.

The retention obligation bites hardest on the incoming side: receipts from suppliers, proofs of payment, records of expenses you want to claim. This is the part that lives in your email inbox, your bank statements, your Stripe dashboard, and your downloaded PDFs.

A system that works for most freelancers: download the invoice at the time of payment, rename it with the date and supplier, and store it in a folder that is backed up offsite. Cloud storage with a reasonable backup policy satisfies the DL 28/2019 digital-archive requirement. The 10-year clock means you want a system you will still be using in a decade, not a folder on a laptop you will probably replace twice before the window closes.

A note on organized accounting and Ldas

The retention obligation is the same whether you are on the simplified regime, on organized accounting (contabilidade organizada), or operating through a Lda. What changes with organized accounting or a Lda is who does the bookkeeping, not who is legally responsible for the records.

The 10-year conservation duty under Art. 52 CIVA and Art. 123 CIRC belongs to you as the sole trader, or to the gerente/administrador if you operate through a Lda. Hiring a certified accountant (contabilista certificado) to handle your books does not transfer that obligation. A contabilidade externa does not eliminate the legal duty of the business owner. If the AT audits you, they come to you, not your accountant.

The CC is responsible for the technical regularity of the accounting. Under the OCC's Código Deontológico they also have a subsidiary liability for tax debts in cases of culpable breach. Neither of those is the same as being the keeper of your business documents. Your archive belongs to your sphere, not theirs.

A practical consequence of this shows up when people switch accountants or change accounting software. On termination of the engagement, the CC must return all documents within 60 days (Art. 15, Código Deontológico OCC). That is a handover obligation, not a guarantee that the documents will be intact or easy to use when they arrive. The digital archive is your property from the start.

The implication for how you structure your setup: keep your own access to the document archive, independent of your accountant's system, and keep a backup stored in a location separate from the primary copy. Portuguese law requires this anyway (cópias de segurança). Do not treat your CC or your software vendor as the fallback for finding documents in year 9.

For the typical expat freelancer reading this: simplified regime, 10 years, paperless is fine under DL 28/2019. That is the short version. Keep your own archive. Make sure it qualifies.

For the longer version of how expenses work under the simplified regime, including the 15% rule and how foreign supplier invoices fit in, the guide to expenses for freelancers in Portugal has everything.

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If you use Descodify, your issued invoices and faturas-recibo are archived automatically through AT-certified infrastructure. For expense records, the platform lets you upload and store receipts alongside the corresponding expense entries.