According to the Portuguese Law, in order to issue electronic invoices: “the taxable persons must assure the authenticity of the origin, the integrity of the content and the legibility of an invoice, from the point in time of issue until the end of the period for storage of the invoice, by means of any business control that creates a reliable audit trail between the invoice and the supply of goods or services”.
These business controls must be properly documented, updated, and made available for consultation by the tax authorities. If the above-mentioned standards are completed, an invoice in pdf-format can be considered an electronic invoice.
Due to the limits imposed by the Covid-19 epidemic, invoices were made available to clients in pdf format despite not meeting the stated requirements (Order no. 129/2020-XXII, of March 27, Order no. 437/2020-XXII, of November 9, Order no. 72/2021-XII, of March 10, Order no. 133/2021-XXII, of April 22, Order no. 260/2021-XXI, of July 27 and Order no. 351/2021-XXI, of Novembro 10) in the following periods: April, May, and June 2020; November 9, 2020, to December 31, 2021; and January 1, 2022, to June 30, 2022.
As a result, in practice, no specific requirements apply to pdf invoices until June 30.
Effective date: 30 June 2022