PDF Qualified Electronic Signatures (QES) delay till Jan 2026
There has been a new 1-year delay to QES, which was scheduled for 1 January 2025, announced in the recent 2025 budget.
Portuguese businesses may continue to use PDF invoices as ‘electronic invoices’ until 31 December 2025. After which, they must include a Qualified Electronic Signatures (QES) from 1 January 2026. QES’ may only be issued to taxpayers by certified third-party providers.
Electronic invoices in Portugal hold equal legal weight to paper invoices. This was part of 2009 reforms. At the same time, annual SAF-T Accounting has also been delayed a year until 2027 (for 2026 transactions).
Jan 2023: 3 reforms for non-resident taxpayers
Since 1 January 2023, the Tax and Customs Authority (AT) now requires foreign businesses VAT registered in Portugal to comply with 3 requirements already in place for residents:
- Invoices must be produced by certified invoicing software that can allocate a unique ATCUD code;
- Paper or PDF invoices must include a QR Code; and
- Monthly invoice reporting via SAF-T Billing file (other options, see below).
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Note, this is separate from the new 2026 annual SAF-T Accounting reporting requirement. See Portugal SAF-T full requirements.
1. ATCUD Sequential Number Validation Code number
A unique 8-digit code, ATCUD, is allocated by AT for batches of invoices prior to their issuance. It is made up of two parts, separated by “-“:
- Service validation code; and
- Unique document code within the batch numbers issued.
ATCUD codes are processed on certified billing systems with batches numbers sourced via AT on an API call. These are held by the system and allocated as the invoice is created.
2. QR code for paper or PDF invoices
This is a two-dimensional bar code – quicker to read by IT systems and holds more data than the traditional barcode. However, the QR code may be bypassed for taxpayers using electronic data interchange (EDI), for the intercompany communication of business documents in a standard format. Most of the fields need to be linked (or ‘mapped’) using SAF-T.
The code contains the following data:
- Supplier tax identification number (TIN)
- Unique UIDD or ATCUD number for the invoice (see below)
- Taxable amount
- VAT amount
- Certified software unique number.
3 Monthly SAF-T Billing submissions
Non residents have to report their invoices to AT. This can be directly to AT via manual interface or webservice. But a third option, monthly SAF-T Billing is the simplest and most popular option. This is produced by certified billing providers.
It must be filled by the 5th of the month following the transaction period.
Portugal SAF-T was introduced in 2009, based on OECD SAF-T standard data exchange regime.
SAF-T Billing is structured as follows:
- Master files: product tables; customers; suppliers; and tax table
- Transaction data: sales and purchase invoices; goods movements; payment information
This information is only obliged when readily available in the taxpayers accounting systems.
