Portugal has again pushed back two digital tax deadlines that businesses had been preparing to meet in January. The draft State Budget for 2027, submitted to Parliament on 8 October 2026, extends the period during which PDF invoices count as electronic invoices, and separately postpones the first mandatory submission of the accounting SAF-T (PT) file.
The two measures appear in the same bill and both move by one year, which makes it easy to read them as a single delay. They are not. One concerns how invoices exchanged between businesses are secured; the other concerns an annual accounting file sent to the tax authority. Each affects different processes and different teams, and neither touches the invoicing controls Portugal already enforces.
Key Dates
| Obligation | Current timetable | Proposed timetable |
| PDF invoices accepted as electronic invoices | Until 31 December 2026 | Until 31 December 2027 |
| Authenticity and integrity required for every electronic invoice | 1 January 2027 | 1 January 2028 |
| SAF-T Accounting: first accounting periods covered | 2027 | 2028 |
| SAF-T Accounting: first submissions | 2028 | 2029 |
Both changes remain proposals. The final parliamentary vote on the budget is scheduled for 24 November 2026.
1. Two Postponements, Two Different Obligations
The distinction is worth setting out before the detail, because the two measures sit in different parts of the Portuguese framework.
The PDF extension belongs to e-invoicing. It governs whether an invoice sent as a plain PDF can still be treated as electronic for tax purposes, or whether it must carry a mechanism proving where it came from and that it has not been altered.
The SAF-T Accounting postponement belongs to tax reporting. It governs when companies must start sending the tax authority a structured annual extract of their accounting records.
A business can be affected by one, both, or neither, depending on how it invoices and how it keeps its books in Portugal.
2. PDF Invoices: One More Year of Transitional Acceptance
2.1 What the Transition Covers
Under the current rules, the tax authority accepts invoices sent as simple PDF files as electronic invoices for all tax purposes until the end of 2026. The proposal carries that treatment through 2027. Without it, the transition would have ended in a few weeks.
Once it ends, an electronic invoice must guarantee two things: the authenticity of its origin and the integrity of its content. Portuguese invoicing rules name three ways to achieve this:
- A qualified electronic signature (QES)
- A qualified electronic seal
- An EDI (electronic data interchange) arrangement backed by an appropriate agreement between the parties
The list is open-ended, and the tax authority has accepted that other controls, such as a reliable audit trail linking the invoice to the underlying transaction, can serve the same purpose.
2.2 Why “QES Delay” Is Only Half the Picture
The measure is often described as another postponement of the qualified signature requirement. That shorthand is understandable, since signing PDFs is the route most businesses had planned. It is also incomplete. Portugal is not postponing a signature rule; it is extending the period during which an unsecured PDF is deemed sufficient.
The practical consequence is that businesses still have a choice of mechanism for 2028, and the extra year is best used to make that choice deliberately. A company issuing high volumes of PDFs may conclude that a qualified seal applied centrally is more workable than individual signatures, or that moving key trading relationships to structured EDI exchange removes the question altogether.
3. SAF-T Accounting: The Annual File Moves to 2028 Periods
The accounting SAF-T (PT) is a standardised file built from a company’s general ledger, covering the chart of accounts, journal entries, customers, suppliers and tax tables. Its main purpose is to feed the pre-filling of the IES (Informação Empresarial Simplificada, Simplified Business Information return), the annual filing that combines accounting, tax and statistical data.
The obligation has existed in legislation since 2019 but has been postponed repeatedly before any mandatory submission took place. The 2027 budget proposal moves it once more, so that it first applies to 2028 accounting periods, with the corresponding files sent in 2029.
For groups with Portuguese entities, the delay is time to address the hard part of SAF-T projects, which is rarely the file format. It is mapping local accounting data to the required structure, particularly where the general ledger, sub-ledgers and master data sit across several systems.
4. What Does Not Change
The proposal leaves Portugal’s existing invoicing controls untouched:
- Certified invoicing software remains mandatory for issuing invoices.
- ATCUD (Código Único de Documento, unique document code) must still appear on every invoice, built from the validation code of the series registered with the tax authority and the document’s sequential number.
- QR codes remain required on invoices and other tax-relevant documents.
- Monthly invoice reporting to the tax authority, typically through the invoicing SAF-T file, continues as before.
That last point is where confusion is most likely. Portugal uses SAF-T for two separate purposes. The monthly invoicing communication has been mandatory for years and is unaffected. Only the annual accounting file is postponed.
The same budget proposal also extends by one year, until the end of 2027, a transitional arrangement for small and medium enterprises in public procurement e-invoicing (B2G), which is a separate regime from the B2B rules discussed here.
5. Planning for 2027
Neither postponement suspends work in progress. For e-invoicing, 2027 is the year to decide how invoice authenticity and integrity will be guaranteed from 2028 and to implement that choice across issuance flows. For SAF-T Accounting, it is the year to test whether ERP data can produce a complete and accurate file before the first periods it must cover begin.
Both measures also depend on the vote in November. Businesses that pause their projects on the assumption that the extensions will pass would have very little time left if the text changes during the parliamentary process.
RTC supports multinational businesses with Portuguese e-invoicing, invoice reporting and SAF-T obligations, alongside their compliance requirements in other jurisdictions.
