Portugal: New Order Establishes Grace Period for Invoice Reporting Obligation and Postpones QES Requirement for E-Invoices

Carolina Silva
December 16, 2022

The Portuguese State Secretary of Fiscal Affairs issued Order 8/2022 XXIII which, among others things, establishes a grace period for invoice reporting obligations, as well as another postponement of the requirement of application of a qualified electronic signature or seal on electronic invoices.

The Order establishes a grace period during which penalties that concern the fulfillment of the invoice reporting obligations, as established by article 3 of Decree-law 198/2012, will not be applied if reporting is carried out until the 8th day of the month following the issuance of the invoice, during 2023.

Additionally, during 2023, there will be the implementation of a system of informative alerts by the Tax authority to taxpayers that do not communicate their invoice data by the 5th day of the month following the issuance of the invoice, in order to promote voluntary compliance with the 5-day deadline. This follows the deadline shortening made earlier this year, by means of Law no. 12/2022, regarding monthly invoice data reporting requirements, which must be submitted on the 5th of each month following the issuance of the invoice, starting 1 January 2023.

Furthermore, this order postpones, once again, the obligation to include a Qualified Electronic Signature/Seal on electronic invoices or to use EDI as per the European Model, and as such explicitly states that until the 31st of December of 2023 all PDF invoices are considered electronic invoices for all fiscal effects.

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Carolina Silva

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