Modelo 22 and IES: what they are, when to file, and late-filing fines

For the full month-by-month calendar of a Portuguese Lda’s tax and legal duties, see the tax and legal calendar (2026).

Modelo 22: the annual IRC return

The Modelo 22 is the periodic income declaration for IRC (Portuguese corporate income tax). It is provided for in the Código do IRC (articles 120 to 122) and assesses the tax owed by the company for the tax period (for most Ldas, coincident with the calendar year).

Content-wise, the Modelo 22 declares:

• The taxable profit derived from the accounting result, with the tax adjustments provided for in the CIRC.
• The tax losses carried forward from prior periods.
• The taxable base (taxable profit minus reportable losses).
• The assessed IRC (taxable base multiplied by the applicable rate).
• The tax benefits used.
• The autonomous taxation on specific expenses (company cars, per-diem allowances, entertainment expenses, among others), each with its own rate.
• The municipal and state surtaxes, where applicable.
• The payments on account and withholdings already made, for reconciliation.

The result is the IRC to be paid (or refunded, when payments on account and withholdings exceed the tax owed).

Legal deadline and the 2026 adjustment

Article 120(1) of the CIRC sets the Modelo 22 deadline at the last day of May of the year following the tax period, regardless of whether that day is itself a working day. For entities whose tax period does not coincide with the calendar year, the deadline is the last day of the fifth month after the end of the tax period, also regardless of whether that day is a working day.

Exceptionally for 2026 (Modelo 22 for the 2025 tax period): the Tax Authority extended the deadline in two steps, through Despacho n.º 68/2026-XXV-SEAF of 12 May (first extension to 19 June) and Despacho n.º 81/2026-XXV-SEAF of 17 June (second extension to 30 June), in response to the impact of the storms at the start of the year. The extension covered both filing and payment, with no fines or interest.

The rule to keep in mind for annual planning: the last day of May (working or not). Extensions are ad hoc measures, not a change to the rule.

Who files and who signs

The Modelo 22 is filed electronically on the Portal das Finanças. Electronic signature by the certified accountant responsible for the company’s bookkeeping is mandatory: without it, the filing is not accepted. In practice, the Modelo 22 is prepared and submitted by the company’s accountant, even though legal responsibility for the accuracy of the data rests with the company and its legal representative.

IES: one filing for several purposes

The Informação Empresarial Simplificada (IES) was created precisely to reduce the number of filings a company has to submit. Instead of filing separately with the Tax Authority, the Commercial Registry, the Banco de Portugal, and the INE, the company files a single declaration — the IES — and the system routes the information to each of these bodies.

The IES covers four legal effects in a single submission:

• Tax (AT): annual accounting and tax information return, complementing the Modelo 22.
• Commercial registry (IRN): annual accounts deposit at the Commercial Registry Office. This is a mandatory step in the year-end closing and follows from a resolution approving the accounts in general meeting. For the approval process and the minutes rules, see the minutes book guide.
• Statistics (INE): statistical information on the company’s activity.
• Supervision (Banco de Portugal): central-balance data.

It is also the moment when eligible entities can confirm the RCBE alongside the IES, where applicable (see the dedicated guide on RCBE deadlines and penalties for the annual confirmation rules).

Legal deadline and how it runs

Article 121(1) of the CIRC sets the IES deadline at the 15th day of the 7th month after the end of the tax period, regardless of whether that day is a working day. For entities whose tax period coincides with the calendar year (the typical Lda case), that means 15 July of the following year. For entities with a non-calendar tax period, the same 7-month rule applies. For 2026 (IES for the 2025 tax period), the deadline for calendar-year filers remains 15 July 2026 — no extension was announced.

Who has to file

The IES obligation applies to, among others:

• Commercial and civil-under-commercial-form companies (Lda, Sociedade Unipessoal por Quotas, SA, etc.).
• Cooperatives and public companies.
• Individual Establishments with Limited Liability (EIRL).
• Branches of non-resident companies subject to organized accounting.
• Individual entrepreneurs (ENI) under organized accounting.

A Portuguese Lda files IES every year, even without activity and even where the fiscal year closed at a loss. Lack of activity or a negative result does not lift the filing obligation.

Who files and who signs

Like the Modelo 22, the IES is filed electronically and requires the electronic signature of the responsible certified accountant, applied using their professional identification number. In practice, both preparation and submission of the IES are handled by the accountant.

How Modelo 22 and IES fit together

Modelo 22 and IES are not overlapping despite sharing much of the same accounting information. In practice:

• The Modelo 22 comes first (May). It assesses the IRC owed, sets the taxable base, and triggers payment (or refund).
• The IES comes later (July). It reports the full financial data for the year, deposits the accounts, and feeds national statistics and the central-balance database.

In practice, the IES comes after the Modelo 22: by the time the IES is prepared, the year is closed, the accounts are approved in general meeting, and the IRC is assessed. That is why the annual cycle of a Portuguese Lda follows this natural cadence: accounts approval in general meeting by 31 March (article 65 of the CSC); Modelo 22 by the last day of May (working or not); IES by 15 July.

Consequences of filing late

The Portuguese Regime Geral das Infrações Tributárias (RGIT) sets out the fine framework for late or missed filings.

Late or missed filing (Modelo 22 or IES). Article 116 of the RGIT (late or missed declarations, covering tax declarations and periodic statistical or similar declarations) sets a fine of €150 to €3,750 per declaration filed late or missed altogether. These are the RGIT base limits; for legal persons (including any Portuguese Lda), article 26(4) of the RGIT doubles both the minimum and the maximum, so the applicable range is in practice €300 to €7,500 per declaration. The specific amount depends on gravity, culpability (negligence or intent), the company’s economic situation, and any benefit obtained.

Late payment of the assessed IRC. Separately and additionally, late payment can carry a fine of 15% to 50% of the unpaid tax in cases of negligence, and 100% to 200% in cases of intent (RGIT), on top of compensatory interest running from the end of the voluntary payment period. Here too, article 26(4) doubles the applicable maximum limits for legal persons.

Reduced fine for voluntary regularization. Article 30 of the RGIT allows the fine to be reduced to 12.5% of the legal minimum provided three conditions are met, cumulatively: (i) no formal notice, complaint, or denunciation has been drawn up and no tax inspection is under way when the company files the missing declaration; (ii) the AT, based on that regularization, notifies the reduced fine; and (iii) payment is made within 30 days of that notification. Regularizing immediately, before any notification or inspection begins, is what opens this window; after that point, article 30 still provides smaller reductions for specific scenarios, but the discount is much less significant.

Impact on accounts deposit. Specifically for the IES, late or missed filing has an effect beyond the fine: the year’s accounts are not deposited at the Commercial Registry. Sustained missed deposits can, in extreme cases, trigger administrative dissolution proceedings (under the Regime Jurídico dos Procedimentos Administrativos de Dissolução e Liquidação, Decree-Law 76-A/2006). Reaching that point requires ongoing non-compliance, but the risk is real.

Practical routine

Five points to keep Modelo 22 and IES under control:

1. Close the books on time. Closing the year and approving the accounts in general meeting by 31 March opens the runway to prepare the Modelo 22.
2. Modelo 22 prepared in April, filed in May. Leaving the Modelo 22 for the last days of the deadline creates unnecessary risk, particularly in years with many adjustments.
3. IES prepared in June, filed in July. The IES is larger and more time-consuming to prepare; starting early avoids delays.
4. RCBE alongside the IES, where applicable. See the RCBE deadlines guide for the annual confirmation rules.
5. Save the receipts. Every submission generates an electronic receipt. Banks, lenders, and potential buyers request receipts for the last few fiscal years often.

In Limitada, the Modelo 22, IES and RCBE deadlines live in the calendar shared with the accountant, with an alert before each obligation, and every receipt is stored with date and author in the accounting section of the Company Card. See Limitada.

This article is for information only. To prepare, correct, or regularize your company’s Modelo 22 or IES, consult the certified accountant responsible for the company’s bookkeeping.