If you have a seat, permanent establishment or tax domicile in Portugal, keep organised accounts and are required to draw up an inventory, you must report that inventory to the Tax Authority electronically, as at the last day of the previous financial year, by 31 January. The rule is Article 3-A of Decree-Law no. 198/2012, in the wording given by Article 41 of Decree-Law no. 28/2019. Taxpayers under the simplified tax regime for IRS or IRC purposes are exempt. If you hold no stock, you must report that fact rather than simply stay silent. For the inventory as at 31 December 2026, filed in January 2027, something changes: taxpayers required to keep a perpetual inventory lose the exemption from valuing it. Missing the deadline is a serious offence, fined between €200 and €10,000.
Who has to file
Article 3-A(1) of Decree-Law no. 198/2012 sets three cumulative conditions. The obligation falls on individuals and companies that:
- have a seat, permanent establishment or tax domicile in Portugal;
- keep organised accounts; and
- are required to draw up an inventory.
One point deserves emphasis because the opposite is still written in a lot of places: there is no turnover threshold. There used to be one, and Decree-Law no. 28/2019 removed it. The Tax Authority confirms this in its own published note on the subject. If you keep organised accounts and hold stock, you file, whatever your size.
The exemption sits in paragraph 3 of the same article and there is only one of them: taxpayers to whom the simplified tax regime for IRS or IRC purposes applies are relieved of the obligation. Nothing else. In particular, non-profit associations are not exempt if they keep organised accounts.
The deadline
The deadline depends on the tax period, and both rules are in Article 3-A.
| Tax period | Filing deadline | Legal basis |
|---|---|---|
| Matches the calendar year | 31 January of the following year | Art. 3-A(1) of DL no. 198/2012 |
| Does not match the calendar year | End of the first month after the period closes | Art. 3-A(2) of DL no. 198/2012 |
An example of the second row: a financial year ending 31 March is reported by 30 April. For the overwhelming majority of Portuguese SMEs the first row is the one that counts — the inventory as at 31 December 2026 is due by 31 January 2027.
What changes in January 2027: the valued inventory
Since Decree-Law no. 28/2019, Article 3-A has required the inventory to be reported valued. In practice that requirement has never fully taken effect, because every State Budget has waived the valuation through a standalone transitional provision. That is why the article's amendment history does not show these waivers: they do not change the article, they suspend it.
The provision now in force is Article 95(1) of Law no. 73-A/2025 of 30 December (the 2026 State Budget), which waives valuation:
- for all taxpayers, for tax periods beginning on or after 1 January 2025 — the filing made in January 2026;
- for taxpayers not required to keep a perpetual inventory, for periods beginning on or after 1 January 2026 — the filing due in January 2027.
Read the second limb the other way round: taxpayers required to keep a perpetual inventory are not exempt from valuation for the 2026 period and must report a valued inventory in January 2027, in the structure set by Portaria no. 126/2019. The Tax Authority says precisely this in the FAQs it added for 2026 (FAQ 5766).
A word on how much weight that should carry: every recent State Budget has pushed these two dates forward by a year. As the law stands, the January 2027 obligation is real. But a 2027 State Budget could postpone it again, and anyone planning system changes around the date should know it is a political date rather than a structural one.
Who must keep a perpetual inventory
The obligation is in Article 12 of Decree-Law no. 158/2009 of 13 July, which approved Portugal's accounting standards system. The exemptions, which is what matters to most businesses, are in the paragraphs that follow.
| Exemption from perpetual inventory | Condition | Legal basis |
|---|---|---|
| Micro-entities | Do not exceed two of three limits: €450,000 balance sheet total, €900,000 net turnover, 10 employees | Art. 12(2) and art. 9(1) of DL no. 158/2009 |
| Agriculture, animal production, beekeeping and hunting | Activity falls within the subparagraph | Art. 12(4)(a) |
| Forestry and forest exploitation | Activity falls within the subparagraph | Art. 12(4)(b) |
| Fishing and aquaculture | Activity falls within the subparagraph | Art. 12(4)(c) |
| Retail points of sale | Sales do not exceed €300,000 nor 10% of global sales | Art. 12(4)(d) |
| Predominantly service activity | Cost of goods sold does not exceed €300,000 nor 20% of operating costs | Art. 12(5) |
If you are a micro-entity, or fit one of these exemptions, the January 2027 filing is still unvalued. If you do not, now is the time to confirm that your invoicing and accounting systems can produce both quantity and value per item as at 31 December, because that is what will be asked for. This is one of the things a disciplined monthly close solves: an inventory that is only reconciled in January is an inventory that gets reported badly.
When there is no inventory
This is the case most often handled wrongly, because intuition says there is nothing to do. Intuition is wrong. Article 3 of Portaria no. 2/2015 of 6 January, headed Taxpayers without inventories, requires anyone holding no stock at the end of the period to report that fact to the Tax Authority, through the Finanças Portal, within the same deadlines. On the portal it is the option "Não possuo existências" — I hold no stock.
A service business with organised accounts and no stock is exactly here: nothing to report, but a report to make. Failing to make it is a punishable omission like any other.
The file: format and where it goes
The file structure comes from Portaria no. 2/2015 of 6 January, as amended by Portaria no. 126/2019 of 2 May, which added the valuation elements. Portaria no. 2/2015 remains in force; it has not been replaced.
Article 4 allows two formats: plain text or XML. This is worth stating plainly because the confusion is widespread: it is not a SAF-T (PT) file. The accounting SAF-T is a separate obligation on a separate timetable — Article 95(2) of Law no. 73-A/2025 defers it to the 2027 period onwards, filed in 2028 or later.
In text format, Article 5 fixes the fields and their order on the file's first line: ProductCategory; ProductCode; ProductDescription; ProductNumberCode; ClosingStockQuantity; UnitOfMeasure; ClosingStockValue, with a semicolon as field separator and a comma as decimal separator. In XML, Article 6 defines the StockHeader and Stock tables, which must validate against the xsd published on the Finanças Portal.
Filing is done at Portal das Finanças > e-Fatura > Inventários > Enviar Ficheiro, and files are reviewed under Inventários > Consultar Ficheiros. On submission you state the file version — 1_02 (unvalued) or 2_01 (valued) — the tax period and the period end date. Resubmitting for the same period replaces the earlier file: the Tax Authority treats the last one as the return, which is the correct way to fix an error found after filing.
One trap to avoid: older Tax Authority pages still give the path "Serviços Tributários > Serviços > Inventários", which is superseded. The current path runs through e-Fatura.
The penalty
Missing the deadline, or filing late, does not fall under the general rule for late returns. It has its own provision: Article 117(9) of the RGIT (Law no. 15/2001, added by Law no. 82-B/2014) classifies it as a serious administrative offence punishable by a fine of €200 to €10,000 where it concerns the reports required by Articles 3 and 3-A of Decree-Law no. 198/2012.
That displaces paragraph 1 of the same article, which sets €150 to €3,750 for late returns and reports generally. Anyone quoting those figures for inventories is quoting the wrong provision.
Two general RGIT mechanisms then apply to that range. Article 24(2) provides that where the law does not distinguish intentional from negligent conduct, negligence may be sanctioned only up to half the maximum. Article 26(4) doubles both the minimum and the maximum where the fine is applied to a legal person or company. Combining the three:
| Offender | Negligence | Intent |
|---|---|---|
| Individual | €200 to €5,000 | €200 to €10,000 |
| Company or other legal person | €400 to €10,000 | €400 to €20,000 |
The ranges in the table follow from reading Articles 117(9), 24(2) and 26(4) of the RGIT together — they are not transcribed from any single provision. Article 29 of the RGIT also provides for reduced fines on voluntary regularisation, which makes filing late of your own accord a materially different decision from waiting for the Tax Authority to notice.
January checklist
- Confirm where you stand: organised accounts and an inventory obligation, and not in the simplified IRS or IRC regime.
- Check whether you must keep a perpetual inventory. That is what decides whether January 2027 is version 1_02 or 2_01.
- Close and reconcile stock as at 31 December before extracting the file, not after.
- If you hold no stock, report the nil position — do not leave it blank.
- Validate the file against the Portaria no. 2/2015 field list, or against the xsd, before submitting.
- Submit through e-Fatura and keep the receipt showing the status "Integrado com sucesso".
- If you find an error afterwards, resubmit: the last file replaces the previous one.
How we help
Reporting inventories is one of those obligations that costs little to do properly and a lot to do late. We handle it as part of our clients' routine accounting, with each client's position confirmed individually — including the question that matters this year, which is the perpetual inventory. Monthly accounting for companies starts at €150 a month. See our accounting services.
Frequently asked questions
Who has to report inventories to the Portuguese Tax Authority?
Individuals and companies with a seat, permanent establishment or tax domicile in Portugal that keep organised accounts and are required to draw up an inventory, under Article 3-A(1) of Decree-Law no. 198/2012. There is no turnover threshold: it stopped being a criterion with Decree-Law no. 28/2019.
What is the deadline for reporting inventories?
31 January of the following year for taxpayers whose tax period matches the calendar year (Article 3-A(1)). Those with a different tax period file by the end of the first month after that period ends (paragraph 2). The inventory as at 31 December 2026 is due by 31 January 2027.
Who is exempt from reporting inventories?
Only taxpayers to whom the simplified tax regime for IRS or IRC purposes applies, under Article 3-A(3) of Decree-Law no. 198/2012. There are no other exemptions. Non-profit associations that keep organised accounts are within the obligation.
Do I have to report a valued inventory in January 2027?
Only if you are required to keep a perpetual inventory. Article 95(1)(b) of Law no. 73-A/2025, the 2026 State Budget, waives valuation for periods beginning on or after 1 January 2026 only for taxpayers that are not required to keep a perpetual inventory. Those that are must report it valued, in the structure set by Portaria no. 126/2019, as the Tax Authority confirms in its FAQs.
What if I hold no stock at 31 December?
You must report that fact to the Tax Authority within the same deadlines, through the Finanças Portal — Article 3 of Portaria no. 2/2015, which corresponds to the "Não possuo existências" option. Reporting nothing at all is a punishable omission, even where there is no stock to declare.
What is the fine for not reporting inventories?
Between €200 and €10,000. Article 117(9) of the RGIT classifies failure to report inventories as a serious administrative offence carrying that fine. Under Article 26(4) of the RGIT both limits are doubled where the offender is a company or other legal person, and under Article 24(2) the maximum is halved where the conduct is merely negligent.
Is the inventory file a SAF-T?
No. Article 4 of Portaria no. 2/2015 allows only plain text or XML, with the fields and structure set out in Articles 5 and 6. The accounting SAF-T (PT) is a different obligation, deferred by Article 95(2) of Law no. 73-A/2025 to the 2027 period onwards, filed in 2028 or later.
Sources
- Decree-Law no. 198/2012 of 24 August, Article 3-A (consolidated text)
- Law no. 73-A/2025 of 30 December (2026 State Budget), Article 95
- Portaria no. 2/2015 of 6 January and Portaria no. 126/2019 of 2 May
- Decree-Law no. 158/2009 of 13 July, Articles 9 and 12 — perpetual inventory
- RGIT (Law no. 15/2001), Articles 24, 26, 29 and 117
- Tax Authority FAQs on inventory reporting (including FAQs 5110, 5766 and 5768)