Portugal transfers: licences and invoicing rules

Decreto-Lei 17/2018 includes receiving, transferring and assisting tourists among the activities of travel and tourism agencies. Article 4 reserves those activities to entities registered in the Registo Nacional das Agências de Viagens e Turismo (RNAVT), or operating under article 10. Turismo de Portugal gives a direct answer in its May 2024 frequently asked questions: transfers are a travel agency activity, so registration in the tourism activity register, RNAAT, is not enough on its own. Diário da República — Decreto-Lei 17/2018. Turismo de Portugal — RNAAT frequently asked questions.

Article 13 allows agencies to use vehicles they own or lease for tourist trips and for receiving, transferring and assisting tourists. Vehicles with more than nine seats require compliance with the conditions for admission to the occupation of public road passenger carrier. Using a vehicle with up to nine seats does not remove the need to establish the legal basis for the activity: vehicle capacity and business registration answer different questions. Diário da República — Decreto-Lei 17/2018.

Turismo de Portugal’s RNAVT registration page describes online prior notification, civil liability insurance, an FGVT contribution and a registration fee. The registration number must appear on contracts and advertising. The published figures date from 2023 and should be checked before applying. Turismo de Portugal — RNAVT registration.

We consulted Decreto-Lei 17/2018 as published, without checking later amendments. An exception to exclusivity covers tourist accommodation businesses, local accommodation establishments and tourism activity operators carrying their customers with their own means of transport. This is not general permission for any business to sell transfers. Diário da República — Decreto-Lei 17/2018.

Under the tourism activity regime, transport must take place within the business’s activities. Article 26 of Decreto-Lei 108/2009, republished by Decreto-Lei 186/2015, permits vehicles with up to nine seats owned, leased or rented by the business, or the use of authorised transport providers. For vehicles with more than nine seats, the text requires public passenger carrier licensing and IMT vehicle licensing. The relevant distinction is the connection between the journey and the tourism activity being provided. Diário da República — Decreto-Lei 186/2015, Annex II.

The same article requires the driver to carry their work schedule and a document identifying the business, the event, initiative or project, the date, the time and the departure and arrival locations, for presentation to competent authorities. This is a requirement of that particular regime. A generic booking confirmation does not automatically establish that these particulars are present or that the journey belongs to the advertised activity. Diário da República — Decreto-Lei 186/2015, Annex II.

A TVDE customer can contract a journey only through prior subscription and reservation on an electronic platform. Lei 59/2026 republishes the regime established by Lei 45/2018 and retains the prohibition on taking street hails or passengers from taxi ranks. Published on 25 August 2026, it takes effect on the first day of the following month: this gives 1 September 2026. A booking received directly by email does not become a TVDE booking merely because it was made in advance. Assembleia da República — Lei 59/2026.

The republished text requires an IMT operator licence, issued for up to five years and renewable, and light passenger vehicles with Portuguese plates and no more than nine seats, including the driver. It also allows taxi-licensed businesses and vehicles to operate as TVDE, following TVDE rules while doing so. The passages consulted did not settle whether this amendment affects transfer businesses operating without platforms. Assembleia da República — Lei 59/2026.

Taxis have their own regime. The historical source consulted, Decreto-Lei 251/98 as published in 1998, describes a business authorisation, a municipal vehicle licence, a taximeter and distinctive markings. We did not verify subsequent amendments and therefore do not use that version as a current requirements checklist. The position of exclusively corporate, non-tourist chauffeur services, and transfers sold directly to businesses, also remains unresolved. We do not conclude that a separate chauffeur vehicle hire licence exists. Madeira and the Azores require their own regional analysis, outside this guide’s coverage. Diário da República — Decreto-Lei 251/98, original text.

Article 4 of Decreto-Lei 28/2019, in the consolidated text consulted, requires, for taxpayers established in Portugal, exclusive use of software previously certified by AT and lists three conditions: previous-year turnover exceeding €50,000, using invoicing software, and being required to keep organised accounts or choosing to do so. The collected sources did not settle whether these conditions operate alternatively or cumulatively. We therefore do not say that falling below the threshold exempts a business from certified software, or that turnover is the only test. Confirm how the provision applies to the actual business with AT or a certified accountant. Diário da República — Decreto-Lei 28/2019, consolidated text.

AT publishes the list of certified programs: check the chosen invoicing system against it. Booking, driver planning and invoicing may use different tools. Exporting service details for accounting is not equivalent to issuing a valid Portuguese invoice or reporting its particulars to AT. Diário da República — Decreto-Lei 28/2019, consolidated text.

Article 7 of Decreto-Lei 28/2019 provides for a QR code and ATCUD on invoices and other tax-relevant documents. Portaria 195/2020 defines the ATCUD using the validation code and the document’s sequential number, with ATCUD: followed by those elements separated by a hyphen. It provides for the code on every page, immediately above the QR code. An internal booking reference is not a substitute for these tax document elements. Diário da República — Decreto-Lei 28/2019, consolidated text. AT — Portaria 195/2020.

Article 35 requires document series to be communicated electronically to AT before use. AT assigns the series code forming part of the ATCUD. Assign responsibility for this before the first document is issued: creating a series in an application does not prove its communication. Diário da República — Decreto-Lei 28/2019, consolidated text.

According to AT’s e-Fatura frequently asked questions, documents issued from 1 January 2023 must be reported by the fifth day of the following month. The stated channels are a webservice, a SAF-T (PT)-based file or entry through the Portal. We recommend separating data preparation, submission and checking the result: an exported file is not proof that AT received it. Whoever handles invoicing should know where to find the outcome of each communication. AT — e-Fatura frequently asked questions for issuers.

Article 19 of Decreto-Lei 28/2019 sets a ten-year retention period for books, records and supporting documents. That tax retention period should not automatically be applied to all operational passenger data. For electronic invoices, article 12 requires the recipient’s acceptance and recognises mechanisms guaranteeing origin and integrity, including a qualified electronic signature, a qualified electronic seal or EDI. We did not research the current position on mandatory qualified signatures for PDF invoices; sending a PDF by email does not establish that every requirement has been met. Diário da República — Decreto-Lei 28/2019, consolidated text.