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PDF invoices remain considered “electronic” one more year in Portugal

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The recent provision adopted in the 2025 Budget further postpones the actual implementation of Portugal’s B2G e-invoicing mandate for SMEs.

The Portuguese government has repeatedly established—and subsequently postponed—a deadline for mandatory e-invoicing in B2G transactions. Although the requirement now applies to large companies, the original deadline for small & medium suppliers of the public sector was January 1, 2021, now resulting in a cumulative delay of five (!) years.

The goal of the Portuguese e-invoicing mandate was to mandate the use of structured CIUS-PT invoice formats based on EN 16931 standards. While it didn’t enforce a specific delivery method or central platform, the government introduced a voluntary platform, “FE-AP,” for public recipients. Other public entities could be reached directly (via point-to-point connections) or through third-party platforms.

However, with this new delay, these efforts are largely undermined, as small & medium companies can continue sending PDFs via email to public administrations until December 31, 2025, as established in the 2025 Budget (article 88) passed earlier this month.

The only current requirement is for PDF invoices to include a QR code generated by certified software.

For more details on e-invoicing in Portugal, check out the corresponding Country Profile.

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