Portugal: Postponed mandatory use of qualified electronic signature (QES) and SAF-T accounting file requirements
2026 Budget Bill delays the mandatory use of qualified electronic signatures in PDF invoices and annual SAF-T accounting file reporting
Portugal’s parliament on November 27, 2025, adopted the 2026 Budget Bill, which, among other things, delays the implementation of the mandatory use of a qualified electronic signature (QES) in PDF invoices, and standard audit file for tax (SAF-T) accounting file requirements.
Background
Portugal has been gradually introducing digital tax compliance measures, including mandatory use of QES in PDF invoices and SAF-T accounting file requirements.
A QES is a digital signature that proves who signed an electronic document and that no one changed it, and authorities treat it like a handwritten signature. Businesses use a QES (or a qualified electronic seal) to show the authenticity and integrity of e-invoices, requiring them to obtain a qualified certificate from an EU-listed trust service provider and embed qualified signing in their billing workflow. This requirement was initially set to begin in July 2021; however, it has been postponed ever since.
In addition, Portugal introduced the mandatory reporting of SAF-T files to the tax administration since 2020. The SAF-T reporting compliance was divided into two different requirements: one for the monthly reporting of the sales and purchase data, and another for the annual reporting of accounting information. While the sales and purchase reporting started in January 2020, compliance with the annual SAF-T accounting report has been postponed multiple times.
Overview of amendments
- QES on PDF invoices: Until December 31, 2026, invoices in PDF format will continue to be accepted and regarded as valid invoices for all purposes under tax legislation. However, starting January 1, 2027, PDF invoices must include a QES to comply with invoicing requirements.
- SAF-T: The first mandatory annual SAF-T accounting file for transactions conducted in 2026 will now be due in 2028. This change provides companies with additional time to adapt their accounting systems and processes.
Next steps
The president of Portugal is expected to promulgate the bill. Businesses may need to review their digital reporting and invoicing processes and prepare for the new compliance deadlines. Further details on technical specifications and registration steps are pending and expected to be released with the publication of the law.
For further information, contact a KPMG tax professional:
Philippe Stephanny | philippestephanny@kpmg.com
Ramon Frias | ramonfrias@kpmg.com