04.28.22

Requirement for e-signatures on PDF invoices

In Portugal, under certain circumstances, a PDF invoice can qualify as an electronic invoice. The Covid-19 pandemic has meant that many countries around the world have had to deal with challenges in the management of their fiscal operations. Part of these challenges have involved governments acknowledging that they must provide some concessions to taxpayers.

During much of Covid, PDF invoices were made available to clients, despite not meeting the stringent requirements to qualify as an invoice.

During the following periods, it was / is permitted that PDFs can qualify as e-invoices, despite not meeting stringent requirements:

• April, May and June 2020;
• 9 November 2020 to 31 December 2021;
• 1 January 2022 to June 30 2022.

This means that up to 30 June 2022, PDFs can be accepted as e-invoices without the need to meet any specific requirements.

At all other times, the PDF must be digitally signed to be accepted as an e-invoice.