Regulatory updates - Portugal

Although the Portuguese budget law for 2025 strongly focuses on tax measurements, it also impacts e-invoicing regulation. With this approval, invoices in PDF format will continue to be accepted and treated as equivalent to electronic invoices until December 31, 2025. In other words, taxpayers sending PDF invoices will be allowed to continue to do so all through 2025.

The mandatory submission of the SAF-T file to the tax authorities has also been postponed. This regulation was initially scheduled for 2026; however, with the state budget approval, it has been delayed to 2027.

The postponement of these mandates means businesses will have an additional year to implement QES on e-invoices. Likewise, postponing the SAF-T submission gives companies more time to make the necessary changes and be prepared when the implementation date becomes effective.

The deadline was first moved to 1 January 2023, then to 1 January 2024, and later to 1 January 2025 in response to the technical and financial challenges businesses faced in adopting QES.

The new Portuguese 2025 Budget Proposal, published on 10 October 2024, includes in number 3 of Article 88 a provision to postpone the QES requirement to 1 January 2026. If approved, PDF invoices without a QES will remain valid for tax purposes until the end of 2025.

Additionally, the mandatory submission of the accounting SAF-T file, originally scheduled for 2026, is proposed to be deferred to 2027 for the 2026 financial year, as outlined in number 2 of Article 88.

The impact of these changes is that businesses will have an additional year to prepare for implementing QES on e-invoices, allowing more time for system updates. Likewise, postponing the SAF-T submission gives companies extra time to ensure their accounting systems are fully compliant.

These changes will take effect if the proposed law is officially enacted.

As of 1 January 2025, a QES will be mandatory for every issued PDF on B2B and B2C transactions, instead of 1 January 2024.

Furthermore, it is important to mention that micro, small, and medium-sized companies must send e-invoices in a CIUS-PT format to public authorities starting from 2025 instead of 1 January 2024.

The provisions reflecting the changes can be seen in the new Budget Law, article 182-A, paragraph 4 for PDFs requiring QES, and paragraph 5 for e-invoicing for the public sector.