Portugal proposes another delay for PDF e‑invoices, to January 2028

Summary

Portugal’s draft 2027 State Budget, submitted on 8 October 2026, would let PDF invoices count as valid electronic invoices until 31 December 2027. That is a further one‑year postponement.
The rule requiring PDF invoices to meet electronic authenticity and integrity requirements, including Qualified Electronic Signatures (QES), would move to 1 January 2028. ATCUD, QR code and SAF‑T invoicing obligations stay as they are.
Parliament still has to approve the measure. The final vote is scheduled for 24 November 2026. It is separate from the new annual SAF‑T Accounting reporting requirement.

Article

On 8 October 2026, the Portuguese government submitted its draft 2027 State Budget to Parliament. It proposes extending the transitional period in which PDF invoices are accepted as valid electronic invoices until 31 December 2027. Portugal has already pushed this deadline back several times, and this would add one more year.

Under the proposal, PDF invoices would not have to meet the legal requirements for electronic authenticity and integrity until 1 January 2028. The main one is a Qualified Electronic Signature (QES). Until then, businesses could keep sending and receiving PDF invoices without QES and still treat them as compliant electronic invoices for VAT purposes.

The postponement is narrow. It does not change Portugal’s current invoicing framework, so these obligations continue as before:

the ATCUD unique invoice identification code
the mandatory QR code on invoices
SAF‑T (PT) invoicing data reporting to the Tax Authority

The measure is not law yet. It is part of the State Budget, which Parliament is still debating, and the final vote is scheduled for 24 November 2026. Until the budget is adopted, businesses should treat the extension as a proposal and keep an eye on the parliamentary process.

The change is also separate from Portugal’s new annual SAF‑T Accounting reporting requirement, which still applies. For the full set of obligations, see the overview of Portugal SAF‑T requirements.

What this means for businesses

If the proposal is adopted, it gives businesses more time to roll out QES‑based signing or move to structured e‑invoicing (for example, via certified invoicing software or Peppol). Businesses should still finish their readiness planning instead of pausing projects, for three reasons:

Portugal has delayed this requirement more than once, so the timing is still uncertain.
The vote is still pending.
Further EU e‑invoicing developments under ViDA are coming.

Sources