Portugal, 19 October 2024

Portuguese Government Postpones QES and SAF-T (PT) Obligations for Electronic Invoices

The Portuguese government has proposed delaying the implementation of qualified electronic signatures (QES) and SAF-T obligations for electronic invoices. These changes are included in the 2025 Budget Law proposal, which was published on October 10, 2024.

QES Delay

Under the proposed law, the requirement to apply a qualified electronic signature/seal (QES) on all electronic invoices would be postponed until January 1, 2026. This means that until the end of 2025, PDF invoices without a QES would be considered valid electronic invoices for all tax purposes.

SAF-T Delay

The obligation to submit Standard Audit File for Tax (SAF-T) data would also be postponed. If the law is enacted, the SAF-T submission would be required from 2027.

Next Steps

The proposed changes are part of the 2025 Budget Law, which must be approved by the Portuguese Parliament must approve. If the law is enacted, these changes would go into effect.