IES 2026: Complete Guide, Submission Deadline, and Tax and Accounting Impact

What is the IES: History and Objectives

The IES was introduced into the Portuguese legal system with the primary objective of simplifying and debureaucratising the fulfilment of declarative obligations by companies. Before its implementation, business entities were obliged to submit the same financial and accounting information to multiple entities, in a time-consuming and error-prone process. Ordinance No. 208/2007, of 26 February, was the legal diploma that established the IES, marking a turning point in the interaction between companies and public administration.

The underlying concept of the IES is information centralisation. Through a single electronic declaration, submitted on the Tax Portal, the system automatically and securely forwards the data to the four recipient entities: the Tax and Customs Authority (AT), the Commercial Registry (which operates as a service of the IRN - Institute of Registries and Notaries), the National Institute of Statistics (INE), and the Bank of Portugal. This approach not only reduces the administrative burden on companies but also improves the quality and consistency of the data received by the different public entities.

In addition to simplification, the IES pursues other strategic objectives:

• Cost Reduction: Reduces administrative and compliance costs for companies by avoiding duplication of effort.
• Administrative Modernisation: Promotes the use of electronic platforms and interoperability between public administration information systems.
• Improved Information Quality: Centralised data collection tends to increase the reliability and consistency of available statistical and tax information.
• Combating Tax Fraud and Evasion: The provision of detailed and harmonised data facilitates analysis and cross-referencing of information by the AT, enhancing the detection of irregularities.

The IES thus represents a fundamental pillar in the architecture of corporate and tax governance in Portugal, reflecting a commitment to efficiency and transparency.

Who is Obliged to Submit the IES and Exceptions

The obligation to submit the IES covers a wide range of entities carrying out economic activity in Portugal, aiming to ensure transparency and compliance with accounting and tax standards. According to Article 117 of the Corporate Income Tax Code (IRC Code) and Article 121 of the Personal Income Tax Code (IRS Code), as well as specific diplomas, the IES is imposed on:

• Commercial Companies and Other Entities Subject to IRC: This includes public limited companies (S.A.), private limited companies (LDA.), single-person limited companies, cooperatives, public enterprises, and other entities with or without legal personality that primarily carry out commercial, industrial, or agricultural activities.
• Sole Traders (ENI) with Organised Accounting: Sole traders who opt for or are obliged to have organised accounting, under the terms of Article 117 of the IRS Code, are also subject to this obligation.
• Other Entities Subject to Account Deposit or Specific Statistical Reporting: This includes associations, foundations, and other legal persons who, although not falling into the previous categories, are legally obliged to deposit their annual accounts or report statistical information to any of the IES recipient entities.

It is crucial to emphasise that the obligation to submit the IES does not cease in situations of inactivity, tax losses, or even company dissolution. As long as the entity maintains its active registration, the obligation to submit the IES persists. In the event of cessation of activity, the IES must be submitted within 60 days of the cessation date, as provided for in paragraph 4 of Article 121 of the IRC Code.

Exceptions to the Obligation

Although the rule is general, there are some important exceptions to consider:

• Individuals without Organised Accounting: Sole traders who fall under the simplified IRS taxation regime (e.g., with income below €200,000, as per Article 28 of the IRS Code) and who have not opted for organised accounting, are not obliged to submit the IES.
• Non-Resident Entities without a Permanent Establishment: Non-resident entities that obtain income in Portugal and do not have a permanent establishment in Portuguese territory are generally not subject to the IES, as their tax obligations are fulfilled through withholding taxes or specific regimes.
• Some Public Administration Entities: Certain central, regional, or local public administration entities, which have specific accounting and reporting regimes and do not engage in commercial activities, may be exempt from the IES.

Determining the obligation requires a careful analysis of each entity's legal and tax framework.

IES 2026 Submission Deadline and Specific Cases

The IES submission deadline is one of the most critical aspects of this declarative obligation, and non-compliance can lead to significant penalties. The general rule is established in paragraph 1 of Article 121 of the IRC Code and paragraph 1 of Article 117 of the IRS Code, which refer to the same deadline logic.

General Deadline for Tax Period Coinciding with the Calendar Year

For the vast majority of companies in Portugal, the tax period coincides with the calendar year, i.e., from 1 January to 31 December. In these cases, the deadline for submitting the IES, referring to the previous financial year, is the 15th day of the 7th month following the end of the tax period. Thus, for the IES referring to the 2025 financial year (IES 2026), the deadline is 15 July 2026.

Practical Example 1:

• Company: "ABC, Lda."
• Tax Period: 1 January 2025 to 31 December 2025 (calendar year).
• Period End: 31 December 2025.
• IES Deadline: 15th day of the 7th month following = 15 July 2026.

Specific Cases of Tax Periods Not Coinciding with the Calendar Year

Some companies may have a tax period different from the calendar year, for example, for reasons of international or sectoral harmonisation. In these cases, the rule of the 15th day of the 7th month following remains, but the count is made from the closing date of the respective fiscal year.

Practical Example 2:

• Company: "XYZ International, S.A."
• Tax Period: 1 April 2025 to 31 March 2026.
• Period End: 31 March 2026.
• Count: Apr, May, Jun, Jul, Aug, Sep, Oct.
• IES Deadline: 15 October 2026.

Deadline in Case of Cessation of Activity

According to paragraph 4 of Article 121 of the IRC Code, in case of cessation of activity, the IES must be submitted within 60 days after the cessation date. This deadline applies even if the cessation occurs in the middle of the calendar year.

Practical Example 3:

• Company: "Delta, Unipessoal Lda."
• Date of Cessation of Activity: 15 September 2025.
• IES Deadline: 15 September 2025 + 60 days = 14 November 2025.

Impact of Public Holidays and Weekends

It is important to note that if the last day of the deadline for submitting the IES coincides with a Saturday, Sunday, or national public holiday, the deadline is automatically extended to the next working day, in accordance with Article 279 of the Civil Code, subsidiarily applicable to tax obligations. However, 15 July is, in most years, a working day, so no extensions are expected for IES 2026.

Structure and Content of the IES: Components and Annexes

The IES is not a single form, but rather a set of declarations and annexes that are completed in an integrated manner on the Tax Portal. Its content is vast and covers a series of financial, accounting, tax, and statistical information, reflecting its multifunctional nature. The modular structure of the IES allows only the annexes pertinent to each type of entity to be completed.

Main Components of the IES

1. Cover Page: Contains the entity's identification data (NIPC, name, registered office, CAE, etc.), the tax period to which the declaration refers, and the identification of the Official Accountant (TOC) or Certified Accountant (CC) responsible.
2. Accounting Annexes: These annexes are essential for the deposit of accounts and the collection of statistical data. They include:
   • Balance Sheet and Income Statement: Fundamental financial information, in accordance with the applicable Accounting and Financial Reporting Standards (NCRF).
   • Cash Flow Statement: Mandatory for entities applying the full SNC.
   • Statement of Changes in Equity: Mandatory for entities applying the full SNC.
   • Notes to the Financial Statements: Contains explanatory notes and complementary information to the financial statements.
   • Management Report: Mandatory for certain entities, in accordance with the Commercial Companies Code (CSC).
   • Legal Certification of Accounts/Auditor's Report: If applicable, for entities subject to a statutory audit.
3. Tax Annexes: These annexes are crucial for the Tax and Customs Authority and detail the company's tax information:
   • Annex A (Tax Information): Contains data on turnover, costs, revenues, assets, and liabilities, disaggregated to allow for tax analysis. This annex is very detailed and includes, for example, the breakdown of income and expenses by category.
   • Annex B (Inventory): Details the inventory of stocks and the valuation method used.
   • Annex C (Transfer Pricing Models): For companies with related party transactions, in accordance with the transfer pricing regime provided for in Article 63 of the IRC Code.
   • Annex D (Transactions with Entities Located in Tax Havens): Information on transactions with entities resident in privileged tax jurisdictions.
   • Annex E (Retained Earnings and Reinvestment Deduction Regime - DLRR): Information on the application of this tax benefit.
   • Annex H (Specific Taxation Regimes): For entities benefiting from special tax regimes.
   • Annex I (Impairments, Adjustments, and Provisions): Details on the recognition and reversal of impairments, adjustments, and provisions.
4. Statistical Annexes: These are completed for the INE and the Bank of Portugal and aim to collect data for the preparation of national and European statistics, namely on business structure, investment, employment, etc.

Key Legal References for Structure and Content

• Corporate Income Tax Code (CIRC): Articles 117 (Ancillary obligations) and 121 (IES/Annual Declaration).
• Personal Income Tax Code (CIRS): Article 117 (Ancillary obligations of taxpayers with organised accounting).
• Commercial Companies Code (CSC): Articles 34 to 49 (Regarding the deposit of accounts and publicity).
• Accounting Standardisation System (SNC): Decree-Law No. 158/2009, of 13 July, and its amendments, which establishes the Accounting and Financial Reporting Standards (NCRF), which determine the content of the financial statements.
• Ordinance No. 208/2007, of 26 February: Diploma that created the IES and establishes the models and completion instructions, being updated annually.

The correct completion of the IES requires in-depth knowledge of accounting and tax legislation, as well as the completion instructions provided by the AT. The complexity of the annexes and the diversity of information requested justify the central role of the Certified Accountant in this process.

Costs Associated with the IES and Fines for Non-Compliance

The submission of the IES, as an electronic declarative act, is free of charge. However, the IES includes an obligation that incurs a cost: the deposit of accounts in the commercial registry. Furthermore, non-compliance with deadlines or incorrect information can result in significant fines.

Account Deposit Fee

The deposit of accounts in the commercial registry, which is carried out in an integrated manner with the IES, involves the payment of a fee of €85. This fee is due at the time of IES submission, and proof of payment is essential for the deposit to be considered valid. The fee amount is established by the Institute of Registries and Notaries (IRN), I.P., and can be consulted in its table of fees. Non-payment of this fee, even with the IES submitted, implies that the accounts are not considered deposited, with the legal consequences arising therefrom.

Fines for Non-Submission or Late Submission

Non-compliance with the obligation to submit the IES, whether due to non-submission, late submission, or incorrect data, is subject to fines provided for in the General Regime of Tax Infractions (RGIT), approved by Law No. 15/2000, of 8 August.

• Non-Submission or Late Submission:
  • The fine for non-submission or late submission of the IES ranges between €150 and €3,750 for individuals and between €300 and €45,000 for legal entities, in accordance with Article 120 of the RGIT (referring to infractions related to income declarations or accounting elements).
  • This amount may be increased in cases of wilful misconduct (intent to defraud the tax authorities), potentially reaching double the maximum limits.
  • The fine is reduced if the declaration is submitted on the taxpayer's initiative before the initiation of the administrative offence proceedings or before the final decision.
• Falsehood or Inaccuracy of Data:
  • The submission of false or inaccurate data in the IES may be sanctioned with fines ranging between €250 and €10,000, in accordance with Article 119 of the RGIT (infractions related to accounting and bookkeeping).
  • In cases of wilful misconduct, the fines can be significantly higher.

In addition to monetary fines, non-compliance with the obligation to deposit accounts can have other serious consequences:

• Impediment to Profit Distribution: Companies that have not deposited their annual accounts cannot distribute profits or advances on profits, in accordance with Article 34 of the Commercial Companies Code.
• Restrictions in the Commercial Registry: Without the deposit of accounts, the company may be prevented from carrying out other commercial registrations, such as changes in management, share capital, or registered office.
• Lapse of Commercial Registration: In cases of repeated non-compliance, the company's commercial registration may be declared lapsed, leading to the official closure of the company.
• Loss of Tax Benefits: Some tax benefits may be conditional on compliance with all declarative obligations, including the IES.

The importance of complying with deadlines and ensuring the accuracy of information in the IES is, therefore, unquestionable, to avoid financial charges and operational restrictions.

Common Errors to Avoid When Submitting the IES

The complexity of the IES, coupled with the diversity of information requested, makes it prone to errors, even by experienced Certified Accountants. Identifying and preventing these errors is crucial to avoid fines, delays, and problems with supervisory entities.

1. Failure to Confirm Entity Classification:
   • Error: Assuming the entity is classified under a specific accounting regime (e.g., SNC-ME, full SNC) or tax regime without verifying the annual conditions.
   • Impact: Incorrect completion of annexes or omission of relevant information, leading to inconsistencies and potential sanctions.
   • Solution: Annually review the classification criteria (turnover, total balance sheet, number of employees) to determine the applicable accounting regime and mandatory annexes. Decree-Law No. 158/2009, of 13 July, and its amendments, define the limits for SNC-ME and full SNC.
2. Inconsistency between IES and Model 22:
   • Error: Values reported in the IES (Annex A) do not match the values declared in Model 22 (Corporate Income Tax Return).
   • Impact: Automatic data cross-referencing by the AT detects discrepancies, generating notifications for correction or tax inspection processes.
   • Solution: Conduct an exhaustive reconciliation between Model 22 and the IES before submitting both. The IRC calculation bases and financial data must be consistent.
3. Omission or Incorrect Completion of Specific Annexes:
   • Error: Failure to complete mandatory annexes for certain operations (e.g., Annex C for transfer pricing, Annex D for transactions with tax havens) or completing them with incorrect data.
   • Impact: Non-compliance with specific obligations, resulting in fines and potential disregard of operations or deductions.
   • Solution: Analyse the company's activity and its operations to identify all relevant annexes. In case of doubt, consult the IES Ordinance for the year in question and the completion instructions.
4. Non-Payment of the Account Deposit Fee:
   • Error: Submitting the IES electronically but forgetting to pay the €85 fee associated with the account deposit.
   • Impact: The accounts are not considered deposited, with all legal consequences (impossibility of profit distribution, restrictions in the commercial registry, etc.), even if the IES has been submitted.
   • Solution: Make the payment of the account deposit fee immediately after submitting the IES, keeping proof of payment.
5. Accounting Classification Errors:
   • Error: Incorrectly classifying accounts in the balance sheet or income statement, which is reflected in the IES annexes.
   • Impact: Distortion of the true and fair view of the company, affecting financial and tax analysis.
   • Solution: Ensure the correct application of the SNC and the POC (Official Accounting Plan) or the accounting system applicable to the entity. Conduct internal reviews and periodic reconciliations.
6. Late Submission:
   • Error: Leaving the IES submission until the last days of the deadline, risking technical problems on the Tax Portal or lack of time for corrections.
   • Impact: Application of fines for late submission, in accordance with Article 120 of the RGIT, which can be substantial.
   • Solution: Plan in advance, start completing and reviewing the IES with plenty of time for any corrections, and submit the declaration a few days before the final deadline.

Attention to detail and a rigorous review by the Certified Accountant are fundamental to minimising the occurrence of these errors.

Frequently Asked Questions about the IES and Clarifications

What is the IES deadline in 2026?

For companies with a tax period coinciding with the calendar year (1 January to 31 December), the deadline for submitting the IES for the 2025 financial year (IES 2026) is 15 July 2026. For other tax periods, the deadline is the 15th day of the 7th month following the end of the respective period.

Who must submit the IES?

Commercial companies subject to IRC (Lda., single-person companies, S.A.), sole traders with organised accounting, cooperatives, public companies, and other entities that are legally obliged to deposit their annual accounts or report statistical information to the recipient entities (AT, IRN, INE, Bank of Portugal) are obliged to submit the IES.

What is the difference between the IES and Model 22?

Model 22 is the annual Corporate Income Tax return, the submission deadline for which is generally by the end of May (or end of June, if the tax period ends on 31 December). Its main objective is to determine taxable profit and tax payable. The IES, in turn, is a more comprehensive declaration, with a deadline of 15 July, which, in addition to containing detailed tax information (Annex A), serves for the deposit of accounts in the commercial registry and for reporting statistical information to the INE and the Bank of Portugal. Although complementary, they are distinct declarations with their own purposes and deadlines, and the tax information in the IES must be consistent with Model 22.

How much does the IES cost?

The electronic submission of the IES is free. However, the deposit of accounts in the commercial registry, which is done through the IES, has a fee of €85, which must be paid for the deposit to be considered valid and effective. Non-payment of this fee invalidates the deposit of accounts, even if the IES is submitted.

What happens if the IES is not submitted?

Failure to submit or late submission of the IES can result in fines ranging from €150 to €3,750 for individuals and between €300 and €45,000 for legal entities, in accordance with the General Regime of Tax Infractions (RGIT). Additionally, failure to deposit accounts prevents the distribution of profits, restricts the performance of other acts in the commercial registry, and can lead to the lapse of the company's registration.

Can I correct the IES after submission?

Yes, it is possible to submit a substitute IES declaration. If the correction is made on the taxpayer's initiative within the legal deadline, no fine is imposed. If the correction is made outside the deadline, but before any action by the AT, the fine may be mitigated. It is essential that corrections are made as quickly as possible to avoid future problems with the authorities.

What is the role of the Certified Accountant in the IES?

The Certified Accountant (CC) plays a central and indispensable role in the preparation and submission of the IES. They are the qualified professional to ensure the accounting and tax compliance of the information, guaranteeing that the reported data is correct, complete, and in line with current legislation (SNC, CIRC, CIRS, etc.). The IES requires the electronic signature of the CC, holding them responsible for the veracity of the accounting and tax data. Their expertise is fundamental to navigating the complexity of the annexes and avoiding errors and non-compliance.

Conclusion and Recommendations for Effective Management

The Simplified Business Information (IES) is much more than a mere bureaucratic formality; it is a central pillar in the tax and accounting management of companies in Portugal. Its multifunctional nature, aggregating four distinct obligations into a single declaration, aims to promote efficiency and transparency, but requires rigour and attention to detail from taxpayers and the professionals who advise them.

Timely and correct compliance with the IES is not just a matter of avoiding fines, but rather a demonstration of good corporate governance and financial soundness. A well-prepared and submitted IES reflects legal compliance, the company's financial health, and its ability to fulfil its responsibilities to the State, the market, and other stakeholders.

Practical Recommendations:

1. Advance Planning: Do not leave the preparation of the IES until the last minute. Start the process of collecting and organising documentation well in advance, preferably immediately after the close of the financial year.
2. Rigorous Review: Conduct an exhaustive review of all annexes and data, ensuring consistency between the IES, Model 22, and the financial statements. Use the validation tools available on the Tax Portal.
3. Legislative Monitoring: Stay updated on changes to tax and accounting legislation that may impact the IES, particularly the Ordinances that annually update the model and completion instructions.
4. Communication with the Certified Accountant: Maintain constant and transparent communication with your Certified Accountant. Provide them with all necessary information in a timely manner and clarify any doubts that may arise.
5. Documentation Archiving: Keep all proofs of submission and payment of the IES, as well as the PDF files of the declaration, for a period of at least 12 years, as required by tax and commercial legislation.
6. Information Analysis: Use the data compiled for the IES as a management tool. The detailed information on the company's activity can be useful for internal analyses and strategic decision-making.

By viewing the IES not as a burden, but as an opportunity to consolidate company information and ensure its compliance, entities can transform this obligation into a lever for more efficient and transparent management.

Call to Action (CTA):

If you have questions about completing the IES or need specialised support to ensure your company's compliance, contact a Certified Accountant. The experience and technical knowledge of these professionals are crucial to ensuring that your IES is submitted correctly and within the legal deadline, avoiding fines and future problems with the authorities.

Sources and Legal References

• Corporate Income Tax Code (CIRC): Articles 117 (Ancillary obligations) and 121 (IES/Annual Declaration).
• Personal Income Tax Code (CIRS): Articles 28 (Simplified regime) and 117 (Ancillary obligations of taxpayers with organised accounting).
• Commercial Companies Code (CSC): Articles 34 to 49 (Regarding the deposit of accounts and publicity of accounts).
• General Regime of Tax Infractions (RGIT): Law No. 15/2000, of 8 August, Articles 119 (Infractions relating to accounting and bookkeeping) and 120 (Infractions relating to income declarations or accounting elements).
• Accounting Standardisation System (SNC): Decree-Law No. 158/2009, of 13 July, and its amendments.
• Ordinance No. 208/2007, of 26 February: Creates the Simplified Business Information (IES) and establishes the models and completion instructions. (Consult the annual Ordinances updating the model).
• Civil Code (CC): Article 279 (Calculation of deadlines), subsidiarily applicable.
• Tax Portal: www.portaldasfinancas.gov.pt (Detailed information and access to IES submission).
• Institute of Registries and Notaries (IRN): irn.justica.gov.pt (Information on account deposits and fees).