Portugal Postpones QES Requirements and SAF-T Submission

The Portuguese Parliament has formally approved Law No. 37/XVII/1, introducing significant delays to the implementation of strict electronic invoicing requirements and digital reporting obligations. This legislative update extends the transitional period for the acceptance of PDF invoices and postpones the mandatory submission of the SAF-T Accounting file.

Extension of PDF Validity and QES Mandate

Standard PDF invoices will continue to be accepted as legally valid electronic invoices for all fiscal purposes until December 31, 2026. From January 1, 2027, any electronic invoice that is not exchanged via Electronic Data Interchange (EDI), including standard PDF documents, must carry a Qualified Electronic Signature (QES) to be considered valid by the tax authorities.

SAF-T Accounting File

The law also revises the implementation schedule for the Standard Audit File for Tax (SAF-T) regarding accounting data. The first mandatory submission of the annual SAF-T accounting file, covering transactions for the 2027 fiscal year, is now due in 2028.

The full text of the Parliament’s decision is available on their official website.

There’s more you should know about e-invoicing in Portugal – learn more about the new and upcoming regulations.