Do you email your invoices as PDFs? Portugal’s 2027 State Budget proposal extends, for one more year, the acceptance of these files as electronic invoices. The measure is still under discussion in Parliament, with the final vote scheduled for 24 November.
What the proposal says
Today, PDF invoices are accepted as electronic invoices until 31 December 2026. The proposal extends this deadline to 31 December 2027. The same proposal also postpones, once again, the obligation to submit the accounting SAF-T file, which would apply to 2028 periods, to be filed in 2029.
A postponement, not an exemption
The law still requires electronic invoices to guarantee the authenticity of their origin and the integrity of their content, through specific means such as a qualified electronic signature or seal. A plain PDF sent by email does not, on its own, meet these requirements. That is why the deadline keeps being extended rather than removed.
An example: a consulting company issues invoices in its software and emails them to clients as PDFs. In 2027, if the proposal is approved, it can carry on doing so. After that, it will most likely need to review its software, how invoices are signed and how they reach clients.
Coming from another country?
If you set up a company in Portugal, you will find invoicing rules of its own: as a rule, invoices are issued in software certified by the Tax Authority (AT) or on the Tax Portal, with an ATCUD code and a QR code. Choosing the right software from the start avoids changes halfway through.
An extra year is an opportunity to handle the transition calmly, rather than leaving it until December 2027.
Guiding these decisions throughout the year is part of our work with every client. Talk to us or book an exploratory meeting.
Sources: Proposta de Lei n.º 110/XVII/2.ª (2027 State Budget proposal), art. 77; Lei n.º 73-A/2025 (2026 State Budget); Decreto-Lei n.º 28/2019; ECO and OCC (8 and 9 October 2026).