Portugal has extended the deadline for delivering Export Certificates of Proof (CCE) for VAT-exempt export transactions, granting relief for invoices issued between 1 November 2025 and 31 July 2026 following technical difficulties with new customs and transport systems. Affected suppliers have until 31 October 2026 to deliver the certificates without penalties.
Portugal has extended the deadline for delivering Export Certificates of Proof (CCE) to suppliers for VAT-exempt transactions, following technical difficulties that delayed certificate issuance.
The measure, set out in Order No. 104/2026-XXV, was signed by Secretary of State for Fiscal Affairs Cláudia Reis Duarte on 21 August 2026.
Under Article 6 of Decree-Law No. 198/90, of 19 June, suppliers claiming VAT exemption on exports are required to deliver the CCE within 90 days from the date of issue of the invoice. The requirement is designed to confirm that goods have physically left the customs territory of the European Union.
Reason for the delay
The order states that the implementation of two new systems, the Integrated System of Means of Transport and Goods (SiMTeM) and the Automated Processing System for Customs Export Declarations (STADAEXP-CAU), introduced in November and December 2025 respectively, created difficulties in the interconnection between the two platforms.
This, in turn, made it harder to confirm the exit of goods from the European Union customs territory and led to delays in the issuance of CCEs.
The order notes that these delays risked making it impossible for suppliers to receive their certificates within the standard 90-day window.
Relief measure
To address the issue, the Secretary of State has determined that the 90-day deadline under point (c) of paragraph 1 of Article 6 of Decree-Law No. 198/90 shall, exceptionally, be considered as met for invoices issued between 1 November 2025 and 31 July 2026.
No surcharges or penalties will apply for non-compliance with paragraph 7 of the same article, provided the CCE is delivered to the supplier by 31 October 2026.
The order states that this exception applies without prejudice to the other requirements set out in the legislation.
The measure applies specifically to CCEs linked to invoices falling within the nine-month window between 1 November 2025 and 31 July 2026, giving affected suppliers until the end of October 2026 to complete delivery.
