In 2021, due to the COVID-19 pandemic, both the deadlines for office 365 email address data electronic invoicing in public contracts and for including digital signatures in invoices and other related documents were extended.
At the end of 2023, with the publication of the State Budget law for 2024, the planned dates underwent further changes.
PDF invoices valid until the end of 2024
Decree -Law No. 28/2019 includes the rules for invoicing and other fiscally important documents and stipulates the conditions under which invoices can be issued and stored digitally.
According to these rules, one of the conditions for invoices sent electronically to be considered valid is the inclusion of a digital certificate, such as a qualified electronic signature or electronic seal. However, the entry into force of these technical requirements has been consecutively postponed.
In 2023, Article 284 of Law No. 82/2023 of the State Budget extended the deadline for issuing invoices in PDF format for another year. This means that invoices issued in this format will continue to be valid as electronic invoices during 2024, without the need for a digital signature. These invoices are considered to be processed electronically and have the same tax effects as invoices issued by other electronic means.
The 2024 State Budget Law also extended the deadline for adopting electronic invoicing within the scope of public contracts for micro, small and medium-sized companies supplying the State.
Electronic invoicing in public contracts postponed until January 1, 2025
The deadlines for electronic invoicing within the scope of public contracts initially provided for in article 9 of Decree-Law no. 111-B/2017 , of 31 August, have been postponed over the years by means of several decree-laws.
The first phase of implementation took place between 2019 and 2020 for public entities (direct State administration bodies and public institutes) that were now required to receive and process electronic invoices.
As for state suppliers, the issuance of electronic invoices became mandatory in 2021, but only for large companies. The same rules should have been applied to other organizations first in 2022, and then in 2023 following another postponement, which ended up not happening.
Now, mandatory implementation for other companies and public entities, as co-contracting entities, is only scheduled for January 1, 2025.
Calendar for the adoption of electronic invoicing in public administration
In summary, the deadlines for implementing electronic invoicing are as follows:
Public contractors: April 18, 2019 ;
Other entities referred to in article 3 of the Public Contracts Code (CCP): 18 April 2020 ;
Large companies that are co-contractors under the CCP: January 1, 2021 ;
Small and medium-sized enterprises, as co-contracting entities under the CCP: December 31, 2024 ;
Microenterprises and public entities as co-contracting entities under the CCP: December 31, 2024 .
What is an Electronic Invoice?
An electronic invoice is a document issued, transmitted and received in a structured electronic format that allows for automatic and electronic processing. To be considered an electronic invoice, the document must be issued by invoicing software certified by the Tax Authority; a simple scan of a manual invoice is not sufficient. It must then be possible to send it from the issuer's system directly to the buyer's system.
