As we previously announced, the Portuguese National Assembly confirmed on 27 November 2025 the approval of the 2026 State Budget, officially validating the postponement of the qualified electronic signature (QES) or digital certificate requirement on invoices.
This requirement will now come into force on 1 January 2027.
Consequently, throughout 2026, companies may continue to issue PDF invoices without a signature or digital certificate, provided they comply with Portuguese regulations: certified software, mandatory ATCUD code and QR code.
The authorities will therefore continue to accept compliant PDFs as fiscally valid documents until 31 December 2026.
From 1 January 2027, however, the qualified electronic signature or digital certificate will become mandatory for all electronic invoices.
This postponement provides companies with an additional year to adapt their invoicing systems and complete their transition to the qualified signature.
ASD Group supports companies with their procedures in Portugal and helps them prepare for the forthcoming qualified electronic signature requirement.
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Source: www.parlamento.pt (Portuguese-language PDF)
