Meal vouchers in Europe Subsidio de refeicao rules in Portugal in 2026
Subsidio de refeicao rules in Portugal in 2026
The Portuguese subsidio de refeicao is the clearest case in Europe of a tax system paying employers to use a card. The daily meal allowance is exempt from income tax and social contributions up to 6.15 EUR when paid in cash with salary, and up to 10.46 EUR when paid onto a meal card. The gap is deliberate, it is large, and it is the entire commercial argument for the product.
What are the 2026 exempt amounts?
| Paid as | Exempt up to |
|---|---|
| Cash, alongside salary | 6.15 EUR per day |
| Meal card | 10.46 EUR per day |
Anything above the ceiling is taxed as ordinary income and carries social contributions.
The card ceiling is not a round number chosen for convenience. It is derived: the base value set for the public sector, increased by 70 percent. That means it moves whenever the public sector figure moves, which is why it is worth checking the current year rather than carrying last year's number forward.
What the difference is worth
Take an employee receiving the full card ceiling of 10.46 EUR per day. Across a year that comes to roughly 2,688 EUR net. Paying the same gross amount in cash, after income tax and social contributions, leaves roughly 2,357 EUR.
The difference is about 332 EUR a year per employee, and it goes to the employee rather than the employer. For a company of two hundred people that is a benefit worth roughly 66,000 EUR a year that costs the employer nothing extra to provide, which is a far easier internal case than most benefits.
Is the meal allowance compulsory?
Not in the private sector. It is mandatory in the public sector and is a widespread convention elsewhere rather than a legal obligation. In practice most companies operating in Portugal provide it, which makes it closer to an expectation than a perk.
How acceptance works, and why Portugal is unusual
Portugal is the one European market where all three acceptance models run side by side, which makes it the best place to see the trade-offs clearly.
- Private networks. The issuer contracts merchants directly and settles outside the card networks. Historically the dominant model.
- Open networks. Cards issued by banks, accepted at any merchant carrying the right category codes, on ordinary card network terms and consumer pricing.
- Mixed. The card runs on a card network, but only works where the merchant also holds an agreement with the voucher company.
The direction of travel matters more than the snapshot. The mixed model has been losing ground, with issuers shifting toward the open network model, where the card is a normal payment card whose issuing ranges are restricted to selected merchant categories. Portugal is therefore the clearest evidence in Europe that a meal benefit does not need a private merchant network to work.
That contrast is worth holding against Italy, where the law requires a contract with every accepting merchant and the private network is not optional.
What a Portuguese programme has to get right
Three things, in order of how often they go wrong.
The ceiling has to track the derived figure. Because the card limit is calculated from the public sector base plus 70 percent, it changes without a headline announcement. A programme that hard codes the number will quietly overpay or underpay.
Cash and card have to be kept apart. The two ceilings are different by design. Paying part of the allowance in cash and part on a card means two exemption calculations against two different limits.
Acceptance still has to be restricted. The higher ceiling exists because the card can only be used for food. A card that behaves like general purpose money does not qualify for the higher figure, whichever network it runs on.
Who provides meal cards in Portugal?
Portugal has no register of authorised issuers, so the market is open in a way Italy and Belgium are not. Two kinds of provider operate side by side: the established voucher companies, which historically ran their own merchant networks, and banks, which issue meal cards as ordinary payment cards with the issuing ranges restricted to food categories.
The bank route is what makes Portugal instructive. It demonstrates that a meal benefit can run entirely on standard card infrastructure, settled through normal acquiring, with no merchant network to sign and no clearing body to join. Where a private network still exists, it is a commercial choice rather than a legal requirement.
What the derived ceiling means for configuration
Because the card exemption is calculated rather than declared, it behaves differently from a fixed statutory figure. The public sector base moves, the 70 percent uplift applies to the new base, and the exempt amount changes without anyone publishing a headline number for the private sector.
A programme therefore needs the ceiling held as configuration rather than assumed in code, an owner responsible for updating it when the base changes, and the ability to apply the change from a date rather than retroactively. Programmes that hard code the figure do not fail loudly. They simply carry the wrong ceiling until someone notices in a payroll review.
Portugal compared
Portugal, Spain and Germany share a structure: no register of authorised issuers, no national merchant accreditation, and acceptance limited by merchant category. What sets Portugal apart is the size of the incentive. Germany's meal subsidy tops out at 7.67 EUR a day and Spain's exemption at 11 EUR, but neither pays a premium purely for choosing the card format. Portugal pays 4.31 EUR a day more for exactly that choice.
Every dated change across Europe sits on the calendar. The acceptance question that decides most programme designs is covered in open loop or closed loop.