Portugal relies on certified invoicing software, ATCUD, QR code and SAF-T. From 1 January 2027 a PDF counts as an e-invoice only with a qualified electronic signature; the draft 2027 budget would move this to 2028. B2G is mandatory for micro, small and medium suppliers since 2026.
A PDF invoice counts as an electronic invoice only with a qualified electronic signature (QES)
2026 State Budget of 27 Nov 2025. The draft 2027 State Budget (8 Oct 2026) would keep PDF valid to 31 Dec 2027 and move QES to 1 Jan 2028; final vote 24 Nov 2026. No micro or small-business QES carve-out was found.
Small-business regime: Micro and small suppliers (statutory categories)
Must receive e-invoices: no · Must issue e-invoices: yes
Micro and small suppliers are in scope of the B2G mandate since 1 Jan 2026. The QES rule for PDF invoices has no carve-out for them in the sources found.
Invoices are issued by certified software carrying an ATCUD code and a QR code, and are reported to the tax authority through SAF-T (PT). eSPap runs the B2G gateway.
Invoicing software must be certified. The certifying body and procedure were not captured in the research.Source: internal research · 15 Oct 2026 · verified 16 Oct 2026 · secondary⚠ unverifiedWe found this in secondary sources or sources disagree; we have not yet confirmed it in the official text.
The period starts: The 10 calendar years following the year of the document
10 calendar years: CIVA art. 52 (wording of DL 49/2025, in force 1 Jul 2025) and Código Comercial art. 40.
Electronic archiving governed by DL 28/2019 arts. 19-21: storage in Portugal or another EU member state; outside the EU only with prior AT authorisation.
Integration points
ATCUD(Every issuer of invoices): Unique document code printed on each invoice, with a QR code.
SAF-T (PT)(Every business with certified invoicing software): File-based invoice reporting to the tax authority.
eSPap FE-AP(Suppliers to public bodies): B2G gateway; Peppol is the alternative.
E-invoicing legislation research, status as of 15 October 2026 (internal evidence log) · einvoice project · 15 Oct 2026 · verified 16 Oct 2026 · secondary · internal document docs/research/einvoicing-legislation-2026-10.md
We found this in secondary sources or sources disagree; we have not yet confirmed it in the official text.
Draft 2027 State Budget (8 Oct 2026) would keep PDF valid to 31 Dec 2027 and move QES to 1 Jan 2028; final vote 24 Nov 2026.
SAF-T accounting is delayed to 2027 or 2028; the exact date was not found.
No QES carve-out for micro or small businesses was found.
B2G dates for large suppliers, penalties, the certifying body for invoicing software and the start of SAF-T invoice reporting are not covered by the research.
Whether a structured-format mandate for domestic B2B exists was not found; PT is shown as scheduled only because of the QES rule for PDF invoices.
Deep links on portaldasfinancas.gov.pt and espap.gov.pt were not captured; only the domain of the former is recorded as a source.