The 2027 State Budget Proposal Would Move the SAF-T Accounting File to 2028 Periods and Keep PDF Invoices Valid as Electronic Invoices Until 31 December 2027
On 8 October 2026 the Portuguese Government delivered to Parliament its State Budget proposal for 2027 (Proposta de Lei n.º 110/XVII/2.ª). According to the reporting that KGT could compare, the proposal postpones the obligation to submit the accounting SAF-T file (SAF-T da contabilidade) so that it applies to accounting periods of 2028 and later, with the first filing in 2029, and states that until 31 December 2027 invoices in PDF format continue to be accepted as electronic invoices for tax purposes. This is a proposal, not law, and the article numbers and exact wording have not been read on the official text; the statements below are therefore marked provisional.
Background
Portugal has two parallel digital-invoicing tracks. The first is the tax-certified invoicing regime, in which invoice data reaches the Tax and Customs Authority (AT) through the SAF-T (PT) invoicing file and the ATCUD code. The second is the new accounting SAF-T, a complete annual file of the accounting and tax data of the company, defined in Portaria n.º 31/2019 of 24 January, that is meant to be submitted through the Finanças portal and to pre-fill the accounting annexes of the annual IES return. In addition, Portugal has been phasing in structured electronic invoicing in public procurement, with exemptions for smaller suppliers.
Press reports on the proposal state that the accounting SAF-T was previously due for periods from 2027, with delivery in 2028. KGT has not found that earlier date in an official text during this run and it is treated as reported, not confirmed. In July 2026 the Government had already signalled that PDF invoices would remain acceptable because of the adaptation costs for companies; that statement is also known only from press and is not relied on here.
The Legislative Change
The change sits in the annual State Budget bill, which is a legislative proposal in Parliament and has no legal effect until it is voted, promulgated and published in the Diário da República. Two provisions are reported. First, the submission of the accounting SAF-T file would apply to periods of 2028 and following, with the reference to Portaria n.º 31/2019 retained, which pushes the first submission to 2029. Second, the bill is reported to provide that PDF invoices are accepted until 31 December 2027 and count as electronic invoices for all purposes under the tax legislation.
A further item is reported by only one source and is not relied on: an extension to 31 December 2027 of the exemption from electronic-invoicing mechanisms in public procurement for micro, small and medium-sized enterprises and the public entities that contract with them. The proposal is also reported not to change the VAT Code.
Scope
The accounting SAF-T applies to entities with commercial, industrial or agricultural activity and organized accounting, including Portuguese permanent establishments of foreign entities, and the file is submitted through a certified accountant. The PDF rule concerns every supplier issuing invoices that are required to be electronic for tax purposes. Neither the exact scope nor any threshold has been read on the official text of the bill.
Timeline
| Date | Event | Status |
|---|---|---|
| 8 October 2026 | Government delivers Proposta de Lei n.º 110/XVII/2.ª (State Budget 2027) to Parliament | Reported by the press; the Budget report was read on the official site |
| To be scheduled | Parliamentary debate, vote, promulgation and publication | Not yet in force |
| 31 December 2027 | Last day on which PDF invoices are accepted as electronic invoices under the proposal | Provisional |
| Periods of 2028 | First accounting periods for which the accounting SAF-T applies under the proposal | Provisional |
| 2029 | First submission of the accounting SAF-T file | Derived from the 2028 period; provisional |
Businesses Affected
Every Portuguese company and every foreign group with a Portuguese entity or permanent establishment that keeps organized accounting is affected, as are the finance, tax and IT teams that run the ERP exports, and the certified accountants who would submit the file. Multinationals that have been planning a 2027 go-live for the accounting file or for structured e-invoices out of SAP should treat the proposal as a possible, not a confirmed, change of calendar.
Required Actions
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Do not stop or re-baseline the Portuguese SAF-T accounting build on the basis of a bill that has not been voted. Keep the 2027 date as the planning date until the final law is published, and prepare a decision point for when the final text is known.
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Obtain the article-level wording of Proposta de Lei n.º 110/XVII/2.ª from the Parliament site and confirm the dates quoted in this update before any program decision.
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Keep the content, completeness and reconciliation work (chart of accounts mapping, opening balances, tax code mapping) on schedule, because it is needed for either date and the file is validated before the IES return can be completed.
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For PDF invoices, confirm with customers and platforms that no change of format is imposed on you before 1 January 2028, and plan the structured-format work with the later date as a possible window, not as a commitment.
Practical Implications
If the bill passes as reported, Portuguese entities would gain roughly one more year for the accounting SAF-T and for the transition away from PDF invoices. The practical risk is the reverse: teams that read a proposal as law, and pause their testing, would lose the time they could have used. The bill can still change during the parliamentary process, and a budget vote does not guarantee that the provisions survive in the same form.
Expected Next Steps
Parliament will debate the proposal in the coming weeks, and the final law has to be published in the Diário da República. KGT will update this note when the final text of the provisions is available, including the exact article numbers and dates. The Tax and Customs Authority can also be expected to publish updated technical guidance on the accounting SAF-T once the date is fixed.
How Can KGT Support You?
KGT is a specialist indirect tax technology firm. We implement and run SAP Document and Reporting Compliance (SAP DRC) and deliver SAP-integrated e-invoicing add-ons where DRC does not yet cover a requirement or where a transformation programme makes a DRC rollout impractical in the available window. Our work is done inside the SAP landscape rather than around it, so VAT determination, document creation, transmission, status handling and reconciliation stay in one place.
For Portugal KGT can assess your readiness for the accounting SAF-T and for structured e-invoicing under both the current and the postponed calendar, build the extraction and mapping from SAP, and set up the validation and reconciliation that the Finanças portal requires before the IES return can be completed.
This update is for information only and is not tax or legal advice. Please consult your tax adviser before acting on it.
