E-invoicing in Portugal: what is actually required, and when.

Portugal does not require business to business electronic invoicing and has no clearance system. What it does require is that invoices come out of software certified by the tax authority, that each one carries a QR code and an ATCUD, and that the data is reported every month. The rule that is about to change is narrower than most summaries suggest: it is whether a plain PDF, sent by email, still counts as an electronic invoice.

Most English-language pages on this subject are written by compliance vendors who sell the solution. This one is written by someone who connects the software and moves the data, and who is not selling you a signature product. It states the law in force, says plainly what is only a proposal, and carries the date it was checked.

The rule that expires on 31 December 2026

Article 95 of Law 73-A/2025 of 30 December, the budget law for 2026, accepts an invoice in a PDF file as an electronic invoice for all tax purposes until 31 December 2026. That sentence has been renewed, one year at a time, in every budget law for several years.

If it is not renewed again, then from 1 January 2027 a PDF stops being an electronic invoice on its own. To keep that status it would need a qualified electronic signature or a qualified electronic seal, or an EDI arrangement that guarantees the origin and the integrity of the document in the same way. Qualified is a specific legal standard, not any digital signature: it means a certificate from a qualified trust service provider.

Note what does not change on that date. You can still send the customer a PDF by email. What changes is the tax status of that file, and therefore what you have to be able to show if the deduction is questioned.

What is on the table, and when it is decided

The government submitted the 2027 budget proposal on 8 October 2026. It would extend the PDF rule to 31 December 2027, and it would also extend to the same date the dispensation that frees micro, small and medium companies from electronic invoicing in public contracts. Reporting of the SAF-T accounting file, already postponed more than once, would move again to periods from 2028, with the first delivery in 2029.

The proposal passed its first reading on 28 October 2026 and goes to a final vote on 24 November 2026. Until that vote and the publication that follows it, none of this is law. Anything you read today that states 31 December 2027 as a fact is describing a proposal.

This is the honest position on 6 November 2026: the deadline in force is 31 December 2026, an extension is likely on the arithmetic of the first reading, and likely is not the same as decided.

If you are a foreign company with a Portuguese VAT number

The obligations come with the registration. A company established elsewhere that is VAT-registered in Portugal issues invoices under Portuguese rules, which means certified software, ATCUD and QR code, and the monthly report. There is no exemption for foreign companies.

The failure I see most often is not the signature question at all. It is a company invoicing Portuguese customers out of its own group system, which is certified nowhere, because nobody told them that the software itself is regulated here. That is a problem to fix before January, whatever Parliament decides about PDFs.

What to do between now and January

Three things, in this order, and none of them depends on the vote.

First, confirm that whatever issues your invoices is on the tax authority's certified list, and that the ATCUD and the QR code are actually on the documents you send. This is a five minute check on a recent invoice and it settles the biggest risk.

Second, ask your billing provider in writing what they will do if the qualified signature requirement starts in January. Most Portuguese billing platforms have this built or in progress. The answer tells you whether you need to do anything at all, and it is their job to have one.

Third, leave the signature purchase until after 24 November. If the extension passes, buying qualified certificates now solves a problem you will not have for another year.

This page is not tax or legal advice. I am not an accountant and I am not a lawyer. I give technical and operational support, and I coordinate with the professionals who do advise you. For how these rules apply to your specific situation, ask your accountant.

Sources and date

Checked on 6 November 2026 against Law 73-A/2025 of 30 December, the budget law for 2026, and the 2027 budget proposal submitted on 8 October 2026 and passed at first reading on 28 October 2026. The final vote is scheduled for 24 November 2026.

I will update this page after that vote. If you are reading it well after November 2026 and the date above has not moved, treat it as out of date and check the current budget law.