Postponement of Digital Signature Requirement in Portugal

Postponement of Digital Signature Requirement in Portuguese invoices for one additional year. The requirement is expected to enter into force by January 2025.

The digital signature requirement in Portugal has been postponed for another year, at least until 31 December 2024, based on the Portuguese 2024 Budget Law. Taxpayers in Portugal can continue to use PDF invoices as 'electronic invoices' during 2024.

Starting from 1 January 2025, it will become mandatory for invoices to include a Qualified Electronic Signature (QES). Notably, these QES can only be issued to taxpayers by certified third-party providers.

This extension provides businesses with additional time to adapt to the upcoming changes in invoicing requirements.

At the moment, taxpayers must comply with the following requirements connected to invoicing in Portugal:

  • The use of certified billing software for issuing compliant invoices, which assigns an ATCUD code to each invoice.
  • Paper and PDF invoices must include a QR code.
  • Monthly reporting of invoicing SAF-T.

Find here more information about the invoicing SAF-T reporting obligation in Portugal.

Before the new postponement was approved, according to Order no. 8/2022-XXIII, of 13/12, the qualified digital signature was expected to be mandatory from 1 January 2024. The proposal for delay was included as part of Portugal's 2024 Budget Law.

Additionally, the annual SAF-T Accounting obligation, initially scheduled for implementation, has also been postponed.

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