Portugal proposes another delay to mandatory PDF e-Invoice Requirements until January 2028

Portugal has proposed extending the acceptance of PDF invoices as valid electronic invoices until December 31, 2027. The measure would postpone stricter authenticity and integrity requirements until January 2028, giving businesses another year to prepare.

Portugal's government has proposed another extension of the transitional rules allowing businesses to use PDF invoices as legally valid electronic invoices. The measure is included in the draft 2027 State Budget, submitted to the Portuguese Parliament on October 8, 2026. It can be found on: https://debates.parlamento.pt/catalogo/r3/dar/s2a/17/02/015S1/2026-10-08?org=PLC&pgs=2-264&plcdf=true&utm_ 

According to the proposal, PDF invoices would continue to be accepted as electronic invoices for all purposes under Portuguese tax legislation until December 31, 2027.

This would represent another one-year postponement, moving the expected end of the transitional period from January 1, 2027, to January 1, 2028.

The proposed measure is included in Article 77(3) of the 2027 State Budget bill.

However, the postponement is not yet legally approved. It remains a legislative proposal and must complete the parliamentary process before becoming law.

What are the current PDF e-Invoicing rules?

Under Portugal's existing legislation, PDF invoices are temporarily accepted as valid electronic invoices without necessarily requiring the stricter electronic authenticity and integrity mechanisms that would otherwise apply.

This transitional arrangement has already been extended several times.

In October 2025, the government proposed postponing the relevant requirements from January 1, 2026, to January 1, 2027.

That extension was subsequently incorporated into Law No. 73-A/2025 of December 30, 2025, which established that PDF invoices would remain accepted until December 31, 2026.

The new 2027 State Budget proposal would extend this period by another year.

If Parliament approves the measure, businesses could continue using qualifying PDF invoices throughout 2027 under the transitional rules.

The proposed extension concerns the simplified acceptance of PDF invoices as electronic invoices. Under the transitional arrangement, businesses can continue issuing invoices in PDF format without necessarily applying a Qualified Electronic Signature (QES) solely to benefit from this temporary recognition. A QES is an advanced electronic signature supported by a qualified certificate and created using a qualified signature-creation device. It provides a legally recognised method of verifying the identity of the signer and protecting document integrity.

Once the transitional period ends, businesses relying on electronic invoices will need to ensure compliance with the applicable requirements for authenticity of origin and integrity of content.

Qualified electronic signatures are one recognised method, but businesses should not assume that every electronic invoice must necessarily use a QES. Other legally accepted methods of ensuring authenticity and integrity may also be relevant.

The proposed postponement would give businesses additional time to evaluate their systems and determine the appropriate technical approach.

Importantly, the proposal does not create a new general obligation for all Portuguese businesses to issue structured electronic invoices from January 1, 2028.

Although the government is proposing additional time for PDF invoices, the measure does not postpone Portugal's existing fiscal invoicing requirements.

Businesses must continue complying with the obligations already applicable to their invoicing systems.

These include:

• ATCUD: The unique document identification code required on relevant invoices and other fiscal documents.
• QR codes: The mandatory QR code containing specified fiscal information on applicable invoices.
• SAF-T (PT) invoicing: The existing requirements for generating and communicating invoicing information to the Portuguese Tax Authority.
• Certified invoicing software: The requirement to use software certified by the Tax Authority where legally applicable.
• Invoice numbering and records: Existing rules for invoice identification, sequencing, retention, and tax reporting.

Therefore, the proposed extension should not be interpreted as a general delay to Portugal's fiscalization framework.

Retailers and POS software providers must continue meeting the technical and operational requirements already in force.

What does the proposal mean for retailers and POS providers?

For retailers, the proposed extension would mean additional time to prepare for stricter electronic invoice authenticity and integrity requirements.

Businesses that currently generate PDF invoices through POS, ERP, or accounting software could continue using their existing workflows during 2027, provided the final legislation confirms the extension and their systems meet other applicable legal requirements.

This may be particularly relevant for retail chains, e-commerce businesses, hospitality operators, and companies processing large numbers of electronic invoices.

For POS software vendors, the proposal could reduce immediate implementation pressure.

Implementation impact and what the business should do

Portugal's proposed extension would allow businesses to continue using PDF invoices as valid electronic invoices until December 31, 2027, provided Parliament approves the measure.

For retailers, e-commerce businesses, and POS software providers, the proposal would create an additional year to prepare for stricter electronic invoice authenticity and integrity requirements.

Businesses should take the following actions:

1. Monitor legislative approval: The proposal is not yet law. Continue following the existing deadline until the final legislation is published.
2. Maintain existing fiscal compliance: ATCUD, QR codes, SAF-T invoicing, and certified software requirements remain applicable.
3. Prepare electronic invoice systems: Evaluate qualified electronic signatures and other legally accepted methods of ensuring invoice authenticity and integrity.
4. Review POS and ERP integrations: Confirm that existing systems can be updated before the transitional period ends.

The source for this text is an article that was published by vatCalc. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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