Regulatory updates - Portugal

Today, the Parliament approved Law No. 37/XVII/1, which has an impact on e-invoicing and SAF-T.

E-invoicing

PDF will be accepted and considered e-invoices for all purposes provided by tax legislation until December 31, 2026. Starting January1, 2027, all non-EDI, including PDF invoices will be required to be signed with QES (Qualified Electronic Signature) to be considered valid for fiscal purposes.

SAF-T

The first mandatory annual SAF-T accounting file for 2026 transactions will now be due in 2028, giving companies more time to adapt.

The Parliament’s decision can be found in their official website via this link.

On October 9, 2025, Draft Law No. 37/XVII/1,  which sets forth the State Budget for 2026, was formally presented by the Minister of Finance to the President of the Assembly of the Republic.

This action marks the beginning of the budgetary procedure in Parliament, which will culminate in the final global vote on the initiative on November 27, 2025.

If approved, there would be a postponement of e-invoices, QES, and SAF-T accounting file requirements for another year. The proposal suggests the following:

• PDFs will continue to be accepted as e-invoices until December 31, 2026. Therefore, QES must be applied to every issued PDF from January 1, 2027.
• SAF-T (PT) accounting file submission would become effective in 2028.

More information on this decision will be published as soon as a determination is reached.

During September, a discussion over results on combating tax and customs fraud and evasion for 2024 and the evolution of the e-invoicing system took place in Parliament. During this discussion, the secretary of state for tax affairs, Cláudia Reis Duarte, announced that efforts to adapt the finance system to VIDA had already begun to meet the 2030 timeline. Although there was no information released as to what this preparation encompasses, the details below are known.

Portugal's e-invoicing system

• Certified Invoicing Software: Since 2021, businesses have been required to use software previously certified by the Portuguese tax authorities for issuing invoices and relevant tax documents.
• E-invoicing: For B2G (business to government) transactions, businesses must issue e-invoices. This obligation began in 2021 for large taxpayers and will be fully implemented by 2026, as the remaining taxpayers will be in scope then.
• SAF-T: Since 2013, companies have been required to generate SAF-T (Standard Audit File for Tax Purposes). This file contains a predefined set of accounting, invoicing, transport documents, and issued receipts, designed to facilitate the collection of relevant tax data by tax auditors, support taxpayers' tax returns, and enable analysis of tax-relevant records. The obligation to submit the SAF-T accounting file becomes effective in January 2027.

Based on Portugal's current mandates and upcoming VIDA regulation, changes are expected to cross-border B2B transactions, such as including the real-time reporting of such data.