AT Sits on 1.35 Million IRS Returns at the Three-Week Mark — 432,000 Refunds Already Out, but Two-Thirds of the 2.1 Million Filed Are Still Unprocessed
By 20 April 2026, taxpayers had filed 2.1 million IRS declarations for 2025 income — but the Autoridade Tributária has finalised only 745,000 of them, leaving roughly 1.35 million in the queue. €164.7 million in refunds is out the door, with the bulk of the seven-week processing window still ahead.
The first three weeks of the IRS 2025 filing season have produced an unusual contradiction. Volumes are running ahead of last year's pace — the Autoridade Tributária e Aduaneira (AT) has received 2.1 million declarations by 20 April, more than a million of them in the first ten days. But the AT has so far liquidated (closed) only 745,000 returns, sending out 432,000 refunds worth €164.7 million. That leaves roughly 1.35 million declarations — close to two-thirds of all submissions — still parked in the queue.
The campaign opened on 1 April and runs through 30 June. AT publishes weekly progress data, and the figures released this week show a slower-than-usual liquidation rate at the same point of the cycle. In the equivalent week of 2025, the agency had already closed 902,000 declarations.
What is causing the slower close-out
Three factors explain the gap. First, the architecture of IRS Automático — the pre-filled return that the AT auto-generates for taxpayers with simple Categoria A or H income — went through a backend rebuild in March to incorporate the second round of the IRS Jovem reform and the revised retenção na fonte tables. The new code has produced a higher-than-normal rate of validation flags, particularly on returns that include household members aged 18 to 35 who qualify for partial IRS Jovem exemption.
Second, the system that cross-references AT data with Segurança Social, the Caixa Geral de Aposentações and pension funds is taking longer to confirm employer-side declarations of dependents and tax-deductible expenses — particularly health, education and rental receipts that taxpayers can report on the e-fatura portal until late February.
Third, the 22 March IT outage at Praça do Comércio that bounced refund transfers and forced the agency to fall back on paper instructions for one weekend's batch — covered in this Brief on 23 March — has added a few thousand cases to a manual review queue that is still being worked down.
What this means for refunds
The €164.7 million already paid is a fraction of what is coming. The Finance Ministry projects total IRS refunds for 2026 of around €3.5 billion, paid to roughly 3.5 million households, with the median refund running close to €1,000. Historically, around 70% of all refunds are processed and credited within 30 days of submission — which means the bulk of the 1.35 million returns now sitting in the queue should clear by mid-May.
Taxpayers can check the status of their declaration on the Portal das Finanças under the menu IRS > Consultar declaração. A return that shows liquidada with a positive number (a saldo a receber) will normally have funds in the IBAN registered with the AT within five to ten working days. Returns flagged as em divergência require taxpayer action; the AT typically gives 15 days to respond before suspending the file.
For the expat audience: three things to remember
The IRS calendar applies equally to foreign residents who hold a Portuguese NIF and meet the 183-day residency test. Three points are easy to overlook. First, the NHR regime (now closed to new entrants) does not exempt the holder from filing — exempt income still has to be reported on the relevant anexo. Second, taxpayers with foreign income need to attach Anexo J and may need to claim foreign tax credits under the relevant double tax treaty. The system flags missing Anexo J more aggressively this year, which is contributing to the validation backlog. Third, refunds can only be paid to a Portuguese IBAN; SEPA accounts in other EU member states are not accepted by the AT for IRS purposes, even though they are accepted for VAT and Segurança Social.
If your IBAN on the Portal das Finanças is wrong or out of date, the refund will be issued by paper cheque to the registered address — and a cheque to a foreign address adds three to four weeks to the process.
What to watch in May
Two milestones will tell us whether the AT is back on its usual rhythm. The first is the weekly liquidation count due on 28 April: a number above 1.2 million for the week would indicate the validation queue is being cleared. The second is the publication of the AT's mid-campaign report, expected in the second week of May, which compares year-on-year processing performance and gives a more authoritative read on whether the IRS Jovem changes are slowing the system structurally or just at the start.
