Portugal: PDF invoices to stay valid until the end of 2027

Portugal wants PDF invoices to count as electronic invoices for one more year: the 2027 draft budget, presented by the government in early October, moves the end of this rule from 31 December 2026 to 31 December 2027. Without the extension, every PDF invoice sent by email would need a qualified electronic signature from January. Parliament votes on the principles at the end of October.

What the draft provides

The vote on the principles is scheduled for 27 and 28 October. This is not the first postponement of the signature requirement — the 2026 budget had already pushed it back by a year.

What would apply without the extension

From 1 January 2027, a PDF invoice in Portugal would only count as an electronic invoice if its origin and integrity are secured — in practice with a qualified electronic signature or a qualified electronic seal. A PDF simply sent by email would no longer be enough.

How Portugal regulates e-invoicing

Portugal takes a different route from Germany:

• No B2B obligation for structured e-invoices. An invoice may only be issued electronically if the recipient agrees; a PDF also counts as an electronic invoice there, provided its authenticity is secured.
• Structured only for the public sector: in public contracts, an e-invoice under CIUS-PT, the Portuguese specification of EN 16931, is required — for large suppliers since 2021.
• Control through reporting: invoice data and accounting reach the tax authority as SAF-T files.

In Germany it is the other way round: since 2025, a PDF has not been an e-invoice but an “other invoice” — signed or not. Only a structured format such as ZUGFeRD or XRechnung counts as an e-invoice; with ZUGFeRD it is the embedded XML that matters, not the visible PDF.

What this means for businesses in Germany

• You receive invoices from Portugal: the German e-invoicing obligation only covers supplies between businesses established in Germany. PDF invoices from Portuguese suppliers stay what they were for you.
• You supply Portugal: you invoice under German law. An invoice under EN 16931 is understood by your customer’s accounting too; whether they accept it electronically is their decision in Portugal.
• You have an establishment in Portugal: then the signature and SAF-T questions affect you directly — a matter for Portuguese tax advice, at the latest after the final vote.

Portugal is the counterpoint to the countries switching at the turn of the year, such as Slovakia and Poland. For the overview by country, see E-invoicing mandates in Europe.

Frequently asked questions

Will PDF invoices remain valid in Portugal in 2027?

If the 2027 budget is passed as proposed, yes — until 31 December 2027. Without the extension, from 1 January 2027 they would need a qualified signature or a qualified seal.

Is there a B2B e-invoicing obligation in Portugal?

There is no B2B obligation for structured e-invoices as in Germany. It is required for invoices to the public sector.

Is a ZUGFeRD invoice suitable for Portuguese customers?

For you as a German issuer, yes: it is built on EN 16931 and readable as a PDF at the same time. Whether the customer accepts it electronically is up to them.

Can E-Rechnung Pro apply a qualified signature to PDF invoices?

No. We create ZUGFeRD and Factur-X and check incoming e-invoices; we do not apply a qualified signature or seal.

In short

• Portugal’s 2027 draft budget lets PDF invoices count as electronic invoices until 31 December 2027.
• Without the extension, they would need a qualified signature or seal from January 2027.
• The accounting SAF-T moves to 2029, for the year 2028.
• Vote on the principles on 27/28 October; nothing changes for supplies to and from Germany.

Receiving invoices from abroad? Check incoming ZUGFeRD, Factur-X and XRechnung files free of charge, without signing up.