The qualified signature requirement is coming... " Contisystems

This year brings some new features in terms of document management that you should be aware of.

Will it change in July 2022?

The implementation of Decree-Law 28/2019 has been successively postponed, but its current date of entry into force is July 1, 2022 (Order No. 351/2021-XXII). Under this Decree-Law, it will be necessary to affix a qualified signature or seal in order for tax-relevant documents issued electronically to be considered valid.

What are fiscally relevant documents?

In addition to the invoice, which includes the invoice itself, the invoice-receipt, the simplified invoice or the document amending the invoice, these are also considered to be fiscally relevant documents:

transport documents;
receipts;
any other documents issued, regardless of their designation, which are capable of being presented to the customer and which make it possible to check the goods or services provided, regardless of the medium on which they are presented to the customer.

What is a qualified signature or seal?

A qualified signature involves placing a qualified certificate on the document using a secure device. The simplest example is a citizen's card reader or a digital mobile key signature. However, for entities wishing to sign documents with the name of the company and not with the name of the person legally representing it, the option will have to be the qualified seal, the version applied to legal persons.

To do this, a certificate must be purchased from a CA(Certificate Authority listed by the European Union) and a secure mechanism (HSM - Hardware Security Module) created to affix this seal to the documents. You can see an example of such a process in the image opposite. But don't worry, it's a simple process that can be completely streamlined at Contisystems.

Is it too late?

No, this is a relatively quick process to implement and Contisystems will do its best to prioritize this over the coming months. However, we know that many companies are leaving this implementation to the last minute, so we expect a greater influx of this type of service. Anticipate this and ensure that your document issuance complies with all the requirements.