Portuguese 2025 Budget Law Proposes a Delay in QES (authenticity & integrity) and SAF-T Obligations

The Portuguese 2025 Budget proposal, published October 10, 2024, includes a provision postponing the requirement to apply a qualified electronic signature/seal (QES) on all electronic invoices. Under this draft law, the QES requirement will become mandatory from January 1, 2026. This means that until the end of 2025, PDF invoices without a QES will be considered valid electronic invoices for all tax purposes.

Postponement of the accounting SAF-T obligation has also been suggested. If enacted, the obligation will be applicable from 2026 and onwards, meaning that SAF-T submission will be required from 2027.

The draft law must be enacted for these changes to be effective.