Portugal Postpones QES and SAF-T requirements

The Portuguese 2024 Budget Law, approved on November 29, 2023, has once again postponed the requirement for applying a qualified electronic signature (QES) to all invoices. Originally expected to become mandatory on January 1, 2024, this change makes the use of a qualified signature optional for an additional year.

The obligation for accounting Standard Audit File for Tax (SAF-T) submission has also been delayed and will be applicable from 2025 onward, with submission required starting in 2026.

Though it has been approved, the Budget Law has not yet been officially published.

Timeline

As of January 1, 2025, a qualified electronic signature will be mandatory for all electronic invoices. The submission of the SAF-T file for company accounting, applicable to the periods from 2025 onward, has been postponed to commence in 2026.

Impact

Until December 31, 2024, PDF invoices without a qualified electronic signature will be considered as electronic invoices for all tax purposes in Portugal. Submission of the accounting SAF-T will only be required from 2026.