Portugal confirms SAF-T Accounting for 2027 records, with first submission in 2028

Portugal has postponed mandatory SAF-T Accounting again. The requirement will apply to accounting periods beginning in 2027, meaning the first mandatory files will be submitted in 2028 and used to support the annual IES reporting process.

Portugal has confirmed the new timetable for the mandatory submission of SAF-T (PT) Accounting files. The obligation will apply to accounting periods from 2027 onwards, meaning that businesses covered by the requirement will prepare their first mandatory accounting SAF-T file based on their 2027 accounting records and submit it during 2028.

The postponement was formally introduced through Portugal's 2026 State Budget Law – Law No. 73-A/2025 of 30 December 2025. Article 95(2) states that the submission of the SAF-T (PT) file relating to accounting, under the rules established by Portaria No. 31/2019, applies to periods from 2027 onwards, to be delivered in 2028 or subsequent periods.

It can be found:  https://diariodarepublica.pt/dr/detalhe/lei/73-a-2025-993270096-994025875?utm 

This is important because the SAF-T Accounting obligation has been postponed several times. Businesses therefore have another year before the reporting requirement becomes operational, but 2027 will be the first accounting year for which the relevant data must be maintained and prepared for mandatory submission.

What is SAF-T Accounting?

SAF-T stands for Standard Audit File for Tax Purposes. In Portugal, businesses already use SAF-T files in different tax processes, but the accounting SAF-T requirement concerns the detailed information held in the company's accounting system.

The SAF-T (PT) Accounting file is intended to provide the Portuguese Tax and Customs Authority, Autoridade Tributária e Aduaneira (AT), with standardized accounting information in a structured electronic format.

The obligation is closely linked to Portugal's Informação Empresarial Simplificada/Declaração Anual de Informação Contabilística e Fiscal (IES/DA), the annual simplified business information declaration.

Under Portaria No. 31/2019 of 24 January, the SAF-T Accounting file must be submitted and successfully validated before the relevant IES can be completed in cases where the SAF-T requirement applies. The accounting data contained in the validated file is then used to pre-fill relevant information in the IES, particularly information included in Annexes A and I.

The Portuguese Tax Authority's current technical information already refers to “IES/DA – declaration for the period 2027 and following – IES with SAF-T (PT)”, confirming how the new timetable is being incorporated into the tax administration's reporting framework.

Who will be affected?

The rules established by Portaria No. 31/2019 connect the SAF-T Accounting submission requirement to entities subject to the relevant IES and annual accounting reporting obligations.

In practical terms, this includes businesses required to maintain organized accounting and submit the relevant IES information. Depending on their legal and tax position, this can include companies carrying out commercial, industrial or agricultural activities, individuals with organized accounting and certain other entities subject to Portuguese accounting and tax reporting requirements.

The obligation can also be relevant for foreign companies operating in Portugal where they have reporting obligations connected with a Portuguese establishment.

Businesses should therefore determine whether their Portuguese entity or permanent establishment falls within the SAF-T Accounting and IES scope rather than assuming the requirement applies only to locally incorporated companies.

How will the process work?

The SAF-T Accounting file is not simply attached to the annual IES declaration.

Under the established procedure, the accounting SAF-T file is first transmitted electronically to the Portuguese Tax Authority.

The submission must be made by the entity's certified accountant – Contabilista Certificado. The AT's official filing instructions state that submission of the accounting SAF-T file must be performed by the certified accountant and requires the identification of both the taxpayer and the responsible accountant.

After submission, the AT validates the file

According to Portaria No. 31/2019, the validation is intended to verify the conformity of the data and confirm that the file structure follows the required SAF-T specifications. The legislation provides for the AT to perform this validation within a maximum of 10 days after submission.

Only after successful validation can the relevant IES process continue.

Data from the SAF-T Accounting file is then used to pre-fill parts of the IES/DA. Importantly, fields pre-filled from the SAF-T file are generally not directly editable. If those values are incorrect, the business may need to correct the underlying accounting information and submit a new SAF-T file rather than simply modifying the IES field manually.

What does the 2027/2028 timeline mean?

The postponement sometimes creates confusion because two different years are involved.

2027 is the first accounting period affected. 2028 is the first submission year.

For a company following the calendar year, transactions and accounting entries recorded between 1 January and 31 December 2027 will therefore form the first annual accounting dataset subject to the mandatory SAF-T submission.

The related file will then be submitted in 2028, ahead of the corresponding IES process and according to the applicable statutory deadlines.

The 2026 State Budget therefore does not mean businesses can wait until 2028 to begin preparing. Their accounting systems need to generate compliant data throughout the 2027 financial year.

The postponement gives companies additional time to verify whether their accounting and ERP systems can generate a complete and technically valid SAF-T Accounting file.

This is particularly important for international businesses using centralized ERP systems. Portuguese accounting requirements may require mappings, local configurations or additional data fields that are not automatically available in a global accounting setup.

Testing the export before the mandatory period begins can therefore reduce the risk of discovering technical problems only when the 2028 filing deadline approaches.

In out view, the postponement provides useful additional preparation time, but businesses should not treat 2028 as the real implementation date. The key year is 2027, because this is when accounting records must already be generated in a form that can ultimately produce a valid SAF-T file. If an ERP system does not capture the required information correctly during 2027, correcting an entire year's accounting data shortly before submission could become a significant compliance project.

For multinational businesses, the main challenge will probably be ensuring that global ERP configurations and Portuguese local accounting requirements are properly aligned. This should therefore be approached as both a tax compliance and accounting-system readiness project, rather than simply an annual filing obligation.

Implementation impact and what the business should do:

Businesses within the scope of Portuguese SAF-T Accounting should prepare their systems during 2026, because the mandatory data period begins on 1 January 2027 for calendar-year taxpayers.

Companies should verify that their accounting or ERP systems can generate the required SAF-T (PT) Accounting file, review mappings and master data, and perform test exports before the mandatory period begins.

Finance and IT teams should also coordinate with the company's certified accountant, who will be responsible for submitting the file to the Portuguese Tax Authority.

Businesses should pay particular attention to data quality because the validated SAF-T file will be used to pre-fill relevant parts of the IES/DA, and incorrect pre-filled data may require correction through a new SAF-T submission.

The key dates are therefore straightforward: 2027 is the first accounting period covered, and 2028 is the first mandatory submission year.

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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