Portugal – Changing Accounting Software and SAF-T (PT): Key Obligations and Technical Requirements

  1. Full migration of accounting records

When switching accounting systems during a tax period, it is mandatory to migrate all accounting entries from the previous system.

Importing only balances from a specific month is not compliant.

Example:

If the change happens in March 2027, and the tax period matches the calendar year, the new software must contain all transactions from 1 January 2027 to 31 March 2027 to ensure the SAF-T (PT) for 2027 includes all records.

  1. Opening balances in December of the previous year

Opening balances must be created in December 2026, ensuring the opening balances on 01/01/2027 match the previous year-end closing balances.

This is a mandatory SAF-T (PT) validation rule.

  1. Prohibition on creating opening balances through standard journal entries

Opening balances may not be recorded as standard accounting entries in month 0 or month 1, as these would be exported to the SAF-T as Transactions in Table 3 – GeneralLedgerEntries.

  1. Correct fields for opening balances

Opening balances must be inserted in the Table 2.1 – GeneralLedgerAccounts fields:

  • OpeningDebitBalance
  • OpeningCreditBalance
  1. Software tools and procedures

Accounting programs typically provide dedicated tools, such as:

  • A specific “Opening” journal, or
  • Internal procedures designed to create opening balances

Both are acceptable if they comply with SAF-T rules.

  1. Official documentation

Full technical specifications are available in the SAF-T (PT) manuals:

https://info.portaldasfinancas.gov.pt/pt/docs/Portug_tax_system/Documents/Ordinance_No_302_2016_of_the_2nd_December.pdf

Conclusion

Changing accounting software requires full technical compliance and meticulous migration of all accounting data. Ensuring correct opening balances and complete transaction migration is essential to avoid SAF-T inconsistencies.

Nominaurea can support clients throughout this transition — from technical assessment and migration to SAF-T validation and implementation of compliant accounting procedures.