SAF-T for Short-Term Rentals in Portugal: What It Is, When You Need It, and How to Send It (2026)
Quick summary
SAFT is not a tax. It is not an invoice. It is the monthly file that tells the Autoridade Tributária what you invoiced.
Most AL hosts get this wrong in one of two directions: they assume Airbnb handles it, or they assume that because they are small, nothing applies to them. Both assumptions cost money.
Four things to hold onto:
SAFT de faturação is monthly and is IN FORCE. Deadline is the 5th of the following month. SAF-T da contabilidade is a different file and is NOT YET IN FORCE for anyone. If you invoice through the Portal das Finanças, your invoices are already communicated and there is no SAF-T file to send. A month with zero bookings is not a month with zero obligations.
What SAF-T actually is
SAF-T (PT) stands for Standard Audit File for Tax, Portuguese version. It is a structured XML file with a layout fixed by the tax authority, originally set by Portaria 321-A/2007 and updated by Portaria 302/2016 — a file that does not follow that structure is simply rejected by the AT.
There are three SAF-T files in Portuguese law, and confusing them is the single biggest source of panic among hosts:
SAF-T de faturação. Monthly. Contains invoices, invoice-receipts, credit notes. This is the one that matters to you. IN FORCE.
SAF-T da contabilidade. Annual, accounting-level, tied to the IES. APPROVED BUT NOT YET IN FORCE. The Orçamento do Estado for 2026 pushed it again — it now applies to periods from 2027 onwards, to be delivered in 2028 or later. That is the ninth postponement of an obligation originally set out in Portaria n.º 31/2019. Nothing to do in 2026.
SAF-T de inventários. Not relevant to accommodation services.
When a blog or a forum post tells you "SAF-T is coming and it will change everything", check which file they mean. Usually it is the accounting one, and usually it is not coming this year.
SAF-T vs normal invoices: the distinction that clears up 90% of the confusion
This is where most hosts get stuck, so it is worth being blunt about it.
An invoice is a document. It is the thing you hand to the guest. It proves the transaction, carries the IVA, and belongs to that specific stay.
SAF-T is a report. It is a monthly export of every document you issued, sent to the AT so they can see your billing activity in full.
One is the transaction. The other is the transmission.
Two consequences follow from that:
You can have an invoicing obligation without a SAF-T obligation. Issuing a fatura-recibo on the Portal das Finanças is invoicing. There is no separate file to send, because invoices issued through the Portal das Finanças are automatically communicated to the AT.
You cannot have a SAF-T obligation without an invoicing obligation. SAF-T is downstream of invoices. No invoices, no file — but see the empty-month rule below, because "no file" does not mean "no action".
There is also a third thing people confuse with both: the ATCUD and the QR code. Those are fields printed on the invoice itself by certified software. They are not a report and they are not SAF-T.
When you DO need to deal with SAF-T
You are inside the certified-software regime — and therefore inside the SAF-T communication regime — if any one of these is true. Not all of them. Any one. The criteria come from Decreto-Lei n.º 28/2019, article 4, together with article 123 of the CIRC and Portaria n.º 363/2010:
Turnover above 50,000 euros in the previous calendar year. Annualised turnover above 50,000 euros in the year you started the activity. You already use any computerised invoicing program, regardless of turnover. You have organised accounting, or opted into it, regardless of turnover.
Two corrections to how this is usually reported.
First, the threshold applies to the taxpayer, not to the property. The obligation attaches to sujeitos passivos and not to activities. If you run three AL units under one NIF, you add them together. Hosts routinely assume each unit gets its own 50,000 euro headroom. It does not.
Second, the software criterion has no threshold at all. Even if your business invoices under 50,000 euros, if you use a computer program to issue invoices, that program must be certified by the AT. This is the trap that catches small hosts who buy a channel manager or PMS with invoicing built in because it looked more convenient than the Portal.
When you probably do NOT need to send a SAF-T file
You issue fatura-recibo on the Portal das Finanças and you are under all four criteria above. Income from furnished tourist accommodation, CAE 55201 or 55204, is taxed under Categoria B, and the income is declared by issuing an invoice to the guest either through certified software or by issuing a fatura-recibo on the Portal das Finanças. In that second case, communication is built in.
Your invoicing is genuinely done by a third party in their own name. A management company that contracts with the guest itself invoices the guest itself. But if it invoices in your name as your representative, the obligation is still legally yours. You can delegate the work. You cannot delegate the liability.
And the exception the original version of this article got wrong: an empty month.
The empty-month rule
If you are inside the monthly communication regime and you issued nothing in a given month, you do not send a SAF-T file — you send a declaration saying so. If you do not issue invoices in a given month, you are legally obliged to inform the AT of that fact through the Comunicação Mensal por Inexistência de Faturação, which is also due by the 5th of the following month. The absence of invoicing is reported directly on the e-Fatura portal, or your certified accountant can handle it on your behalf, and failure to meet this requirement can result in financial penalties.
For seasonal AL this is the most commonly missed obligation of the entire year. A coastal unit closed from November to February is four declarations, not four quiet months.
How to send it
Four routes exist. Pick the one that matches your setup.
Route 1: Portal das Finanças, fatura-recibo. Nothing to send. Communication happens at the moment of issue. Only remaining task is the inexistência declaration in months with no billing.
Route 2: Certified software with webservice communication. Each document is transmitted to the AT as it is issued. No monthly file, no monthly upload, nothing to forget. If you are already paying for certified software, this is the setting to turn on.
Route 3: Certified software with monthly SAF-T export. Generate the SAF-T file in your invoicing software, then import that file into the Portal das Finanças to communicate the data to the AT. In practice: log in to the e-Fatura portal with your NIF and Portal das Finanças password, go to Efatura, Emitente, Enviar ficheiro, and submit. Keep the submission receipt.
Route 4: Manual entry on the portal. Viable only at very low document volume.
The deadline in all cases is the 5th. Delivery of the SAF-T (PT) billing file to the AT is due by the 5th of the month following invoice issue, and that rule is unchanged for 2026. The AT has at times applied administrative tolerances allowing delivery up to around the 8th, published month by month on the Portal das Finanças, but the legal deadline remains the 5th and late submission can carry penalties even when the system technically accepts the file. Treat any tolerance as luck, not as a schedule. In one recent case the government did formally extend it: a despacho from the Secretary of State for Tax Affairs allowed December 2025 invoicing to be communicated without penalties until 9 January 2026, because the 5th fell on the second working day after New Year.
Penalty amounts are reported inconsistently across accounting blogs, with ranges from a few tens of euros to five figures depending on which infraction under the RGIT is applied and whether negligence or intent is found. Do not plan around a number. Plan around the date.
The Airbnb myth, precisely stated
Airbnb does not invoice your guests for you, and Airbnb does not submit SAF-T. The document the guest downloads from Airbnb is a platform receipt, not a Portuguese fatura.
Issuing invoices in Alojamento Local is mandatory in Portugal even when the booking comes through Airbnb or Booking. Even where the platform collects the payment, the holder of the activity is obliged to issue an invoice to the final guest in their own name. The platform's commission invoice is treated separately, as an expense of the AL, with withholding or IVA autoliquidação depending on where the provider is established.
Practical detail that trips people up: the invoice goes in the guests' name and never in the name of the booking platform, and it covers the total accommodation value including cleaning and other charges, excluding the service fee Airbnb charges the guest directly.
On IVA, the invoice carries the reduced rate of 6% on the mainland, 5% in Madeira and 4% in the Azores, unless an exemption applies. On withholding, accommodation services are excluded from IRS withholding, so the fatura-recibo should be issued with "Sem retenção – art. 101.º, n.º 1, al. a) CIRS". This particular field is a frequent error, and older guides still say the opposite. Confirm your own setup with your accountant.
Four use cases
One unit, Sesimbra, 22,000 euros a year, isento article 53, invoices on the Portal das Finanças. No certified software required. No SAF-T file ever. Real obligation: the inexistência declaration for every closed winter month, by the 5th.
Three units, Albufeira, 78,000 euros combined under one NIF. Over the threshold on aggregate turnover, even though no single unit is. Certified software is mandatory. Best move is webservice communication so there is no monthly file to remember.
One unit, 31,000 euros, host buys a PMS with built-in invoicing. Under the turnover threshold, but now using a computerised invoicing program — which pulls the host into the certified-software regime regardless of turnover. If that PMS is not AT-certified, the host is non-compliant while feeling more organised than before. This is the most common accidental breach in the sector.
Host uses a management company. Two invoice flows exist: the company's invoice to the host for its service, and the guest invoice for the stay. Establish in writing which entity issues the guest invoice and in whose name. If it is in your name, the SAF-T obligation is yours.
Where things actually break
Not at the SAF-T step. At the data step, every time.
Guest identification incomplete at the moment of invoicing, especially non-resident guests without a Portuguese NIF. Note that below 1,000 euros the acquirer does not have to be identified, but above 1,000 euros the acquirer's identification data is mandatory, and a foreign guest without a NIF can be identified by passport number.
Municipal tourist tax handled inconsistently — sometimes inside the accommodation line, sometimes as a separate line, sometimes forgotten entirely, and the treatment differs between guest-settles and host-settles municipalities.
Stays that cross a month boundary, where the invoice date and the stay date fall in different reporting periods.
Cancellations and partial refunds that need credit notes rather than edited invoices.
Closed months where nobody files the inexistência declaration.
Every one of those is a data problem that arrives long before the XML.
Where EazyAL fits
EazyAL is not certified invoicing software and does not pretend to be. Generating SAF-T legally requires software certified by the AT, and that is a hard legal boundary, not a product gap.
What EazyAL does is fix the layer underneath: the guest, booking and revenue data you already have to collect for SIBA and AIMA is the same data your invoice needs. Names, document numbers, nationalities, arrival and departure dates, nights, unit, gross amount, and the correct municipal tourist tax for that specific município — held once, verified once, and handed to your certified invoicing tool in a clean structure.
Airbnb and Booking, into EazyAL for guest and revenue data, out to certified invoicing software, which issues the invoice and communicates it to the AT.
The result is that the invoice is right the first time, which is the only reliable way to make the SAF-T step boring.
FAQ
Do all Airbnb hosts in Portugal need to submit SAFT? No. Hosts under all four criteria of Decreto-Lei 28/2019 who invoice through the Portal das Finanças have no SAF-T file to submit, because those invoices are communicated automatically. Hosts using any invoicing program, or above 50,000 euros turnover, do.
Is the 50,000 euro threshold per property or per host? Per taxpayer. Multiple units under the same NIF are added together.
If I had no bookings last month, do I do nothing? No. You file the Comunicação Mensal por Inexistência de Faturação on e-Fatura by the 5th.
Does Airbnb submit SAFT on my behalf? No. Airbnb never submits SAF-T and never issues your guest invoice. Your invoice, in your name, to the guest.
Is SAF-T da contabilidade something I need to prepare for in 2026? No. It applies to periods from 2027, deliverable in 2028 at the earliest, and has been postponed repeatedly.
Can SAFT be fully automated? Yes, if the automation ends in certified software. Booking data automation upstream plus AT-certified invoicing plus webservice communication means you never touch an XML file.
Final takeaway
SAF-T is not universal and it is not optional. Which of those applies to you comes down to one question: how do you issue invoices?
Portal das Finanças, small operation, under the thresholds — you are already communicating and you only need to remember empty months.
Any invoicing software, or over 50,000 euros — certified software is mandatory, and communication happens either per document by webservice or once a month by the 5th.
Everything else, including the file itself, is a formatting problem that certified software solves for you. The part that is actually yours is the data.
