Portugal e-invoicing in 2027: what changes for construction companies

The 2026 State Budget, Lei 73-A/2025 of 30 December, sets both:

• Art. 260(2) extends until 31 December 2026 the exemption from electronic invoicing in public contracts for micro, small and medium enterprises. From 1 January 2027, unless extended again, SMEs invoicing public entities must send structured e-invoices.
• Art. 95 provides that until 31 December 2026 invoices in PDF files are accepted and treated as electronic invoices for all tax purposes.
• Art. 95(2) also sets the SAF-T (PT) accounting file submission as applicable to periods from 2027, filed in 2028.

Portugal implements the European e-invoicing standard EN 16931 through a national profile called CIUS-PT, in UBL and CII syntaxes. Structured e-invoicing to public bodies (B2G) has been mandatory for large companies since 2021. According to the public shared-services agency eSPap, the obligation comes from the transposition of Directive 2014/55/EU into the Public Contracts Code.

For construction, this matters mainly to contractors on public works invoicing a municipality, the State or another public entity. If your Portuguese company is an SME with public contracts, from 1 January 2027 the invoices you issue to those bodies must be CIUS-PT files sent through an accepted channel, not PDFs. Your invoicing software provider is the one to confirm readiness.

Under Decreto-Lei 28/2019, art. 12, an electronic invoice requires the recipient’s acceptance and a guarantee of authenticity of origin and integrity of content — in particular a qualified electronic signature, a qualified electronic seal (eIDAS) or EDI under an agreement. The transitional rule in the 2026 Budget suspends that for PDFs until 31 December 2026.

The common reading among Portuguese software providers is that, from 1 January 2027, a plain PDF emailed by a supplier no longer counts as an electronic invoice unless it carries one of those guarantees. This is a consequence of the transition ending rather than a new rule, and it has been deferred several times, so treat it as the expected position, to be confirmed after the 2027 Budget.

For a site team the change is mostly invisible: suppliers of concrete, steel and aggregates will keep sending PDFs, but signed ones. What does not change is the checking: the invoice still has to match what was delivered on the guias de remessa and the agreed contract price.

No. As of 29 September 2026 Portugal has no general obligation for structured B2B e-invoicing between private companies, and we found no announced domestic B2B mandate. What Portugal does have is invoice reporting: invoices are communicated to the tax authority (e-fatura), and every invoice and transport document carries a unique ATCUD code.

At EU level, the VAT in the Digital Age (ViDA) package was adopted on 11 March 2025. According to the European Commission, it allows member states to introduce domestic e-invoicing mandates and moves intra-EU B2B transactions to e-invoicing and digital reporting from 1 July 2030. How and when Portugal will use that option has not been announced.

The European Commission’s “eInvoicing in Portugal” country page is a common source in English, but it is out of date: last updated 14 August 2025, it still gives 1 January 2025 for SMEs and 1 January 2026 for qualified signatures on PDFs. Both dates were pushed back by the 2026 State Budget. Use the Diário da República text of Lei 73-A/2025 (or the Ordem dos Contabilistas Certificados analysis of it) for current dates.

Audiree is not e-invoicing software: it does not issue, sign or submit invoices, and it does not validate signatures or ATCUDs with the tax authority. It reads the invoices and delivery notes your obras receive — photo, PDF or email — with AI and checks each line against the contract, saving the time of manual checking. Documents arrive the same way after 2027. Read more on construction paperwork in Portugal.