In a significant development outlined in Portugal’s 2025 Budget, the recognition of PDF invoices as “electronic invoices” has been extended for another year. This decision aligns with the broader delay in the B2G (Business-to-Government) e-Invoicing mandate for SMEs, which is now set to come into effect on December 31, 2025. Originally scheduled for January 1, 2021, the cumulative delay now spans five years.
PDF Invoices Remain Valid Through 2025
Until the new deadline, PDF invoices will continue to be considered compliant as electronic invoices for transactions with public administrations. However, these invoices must meet a key requirement:
- Inclusion of a QR code generated by certified invoicing software.
This extension allows SMEs additional time to adapt to the planned transition to structured e-Invoicing formats based on CIUS-PT (Core Invoice Usage Specification for Portugal), aligned with the EN 16931 standards.
B2G e-Invoicing Mandate: A Brief Overview
Portugal’s e-Invoicing mandate for public sector transactions was introduced to promote standardized, digital invoicing practices. While large companies are already required to comply, the rollout for SMEs has faced repeated delays. The initiative ultimately seeks to:
- Mandate the use of CIUS-PT structured invoice formats.
- Support voluntary adoption of the FE-AP platform, allowing public entities to receive invoices digitally.
- Facilitate direct point-to-point or third-party platform delivery of e-Invoices.
Implications of the Extended Deadline
While the extension provides relief for SMEs, it also highlights ongoing challenges in achieving full compliance with e-Invoicing standards. Key implications include:
- Continued Use of PDFs: SMEs can still email PDFs to public administrations through 2025, maintaining the status quo for one more year.
- QR Code Compliance: Despite the delay, invoices must include a QR code generated by certified software, ensuring a minimal level of digital compliance.
- Preparation Window: SMEs now have an additional year to invest in certified invoicing solutions and transition to structured CIUS-PT formats.
What SMEs Should Do Now
While the deadline extension offers more time, businesses should leverage this opportunity to prepare for the upcoming requirements:
- Adopt Certified Software: Ensure your invoicing tools can generate QR codes and support CIUS-PT structured formats.
- Familiarize with CIUS-PT Standards: Learn the specifications of structured invoice formats based on EN 16931.
- Explore the FE-AP Platform: Consider using Portugal’s voluntary e-Invoicing platform for streamlined public sector invoicing.
Portugal’s decision to extend the recognition of PDF invoices as electronic invoices reflects an effort to balance regulatory progress with the realities businesses face. While this extension provides relief for SMEs, the transition to structured e-Invoicing formats is inevitable.
Stay ahead of the curve by preparing for the shift now. For more information on Portugal’s e-Invoicing requirements and compliance solutions, visit our detailed guide on B2G e-Invoicing. Don’t delay – start preparing today!
