How to send PDF invoices legally in Portugal

Starting January 1, 2025, PDF invoices in Portugal must meet authenticity requirements by including a qualified electronic signature to be considered valid documents. The Business@Mail solution facilitates automated compliance for signing and sending invoices, their traceability, and legal storage for both EDI and non-EDI clients.

Requirements for issuing electronic invoices in Portugal

Decree Law No. 28/2019 establishes the conditions for issuing electronic documents, encouraging the adoption of an electronic invoicing and document archiving system that allows companies to reduce compliance costs while promoting the development and use of new technologies.

Article 12 of this decree sets the following requirements for issuing electronic invoices:

• Invoices and other documents of fiscal relevance may be issued electronically with the recipient's prior acceptance.
• The authenticity of the origin and integrity of the content of electronically issued documents shall be considered guaranteed if one of the following procedures is adopted: 
  • Applying a qualified electronic signature in accordance with the legal provisions. 
  • Applying a qualified electronic seal in accordance with Regulation (EU) No. 910/2014. 
  • Using an electronic data interchange system, provided that the respective issuers and recipients enter into an agreement in line with Commission Recommendation No. 1994/820/EC.

Adaptation period until December 31, 2024

The Portuguese government has made various adaptations to the fiscal calendar to facilitate compliance with the requirements announced by Decree Law No. 28/2019. While the deadlines have been extended, it is advisable to plan for the mechanisms and solutions for compliance. As of December 31, 2024, the qualified electronic signature of PDF invoices will be mandatory.

What does a qualified electronic signature mean?

According to Regulation (EU) No. 910/2014 of the European Parliament and of the Council, an electronic signature must be a service provided by a qualified trust service provider (eIDAS) that has the relevant accreditations and the appropriate technology to provide specific electronic identification services such as electronic signatures.

In accordance with the eIDAS Regulation, EDICOM is approved as a trusted third party for the provision of the following services in the European Union:

• Creation, verification, and validation of electronic signatures, electronic seals, and electronic time stamps, certified electronic delivery services, and related certificates.
• Preservation of electronic signatures, seals, or related certificates.

How to automate the sending of PDF invoices in Portugal

EDICOM offers companies the possibility to optimize their electronic document sending operations, including invoices in PDF format. Through the Business@Mail solution, it is possible to send all types of electronic documents to 100% of trading partners, whether they have EDI capabilities or not, including customers, suppliers, collaborators, or any other partner.

Mass sending of electronic invoices in PDF format is done without the need to print or scan the documents. The process is as follows:

1. The sender generates a data file from their management system, agreed upon with EDICOM, to generate electronic invoices.
2. The EDICOM platform converts the data to the required standard in each case (UBL, XML, EDIFACT...) and applies a qualified electronic signature to each invoice.
3. EDICOM recognizes the recipient of each invoice, and when the customer is not an EDI partner, the invoice is published in Business@Mail in its electronic format along with a visual representation PDF of the same.
4. Business@Mail sends an email notifying the recipient of the availability of invoices for viewing or downloading, generating different acknowledgments of receipt in accordance with the Portuguese VAT Code.

Advantages of the Business@Mail solution

Business@Mail brings high-value benefits to the company issuing the documents as well as to the customers using the platform to receive invoices in PDF format.

• Optimizes administrative tasks by automating all repetitive tasks. In addition to eliminating the use of printers, which results in savings in paper, ink, and maintenance.
• Effective delivery: It is immediate and secure, arriving within seconds through secure and trusted communication channels.
• Total traceability of the delivery: All actions are recorded through status notifications (sending, reception, viewing), allowing control over whether the partner has accessed the documents sent to them.
• Integrates with any management system without altering the company's usual operations.
• Provides more guarantees, agility, and control than conventional email delivery. It also represents a significant saving of resources by not having to issue and process invoices using analog methods.

An important point to highlight is that the traceability of this solution also allows compliance with the obligation to generate acknowledgments of receipt in credit notes by the recipient, as established by the Portuguese VAT Code.