Document management compliant with DL 28/2019: a guide for Portuguese industry

In a garment factory near Famalicão, the archive of delivery notes lives in three places: a ring binder in the office, a shared folder on the server that no one knows who backed up, and the personal inbox of the lady in administration who has been with the company for 30 years and retires in March. When the parent brand asks for the traceability of a batch from 18 months ago for a sustainability audit, the answer takes three days and involves a phone call to the retired lady. This is not an organisational failure. It is the norm in Portuguese industry.

The thesis of this article is uncomfortable: DL 28/2019 did not oblige you to do anything new in terms of document management — it obliged you to certify your invoicing. True document management, the kind that changes operating costs, is a decision that remains optional, deferred, and that is why it is where most industrial SMEs lose money every month without realising it.

Let me be more precise about what is at stake. The overwhelming majority of the Portuguese business fabric are micro and small enterprises — according to INE, more than 99% of companies in Portugal are SMEs and the vast majority of those are micro-enterprises with fewer than ten people. This is the country of the 40-worker garment factories, of the sole-making factories running a shift and a half, of the family distributors with a 4,000 m² warehouse and a single administrative manager who knows everything by heart. It is in this fabric that document management plays out — and it is in this fabric that it is almost never treated as a project, but rather as a problem that "will sort itself out in time".

The real operational problem

Let us begin with the cost that no one measures. Manually processing an invoice costs on average around 13 dollars; automation reduces that figure to close to 3 dollars (Ardent Partners / IOFM, 2022). Multiply that by the number of supplier invoices your company receives per month. A medium-sized textile factory easily receives 400 to 800 invoices monthly across yarns, dyes, accessories, subcontracting and services. The sum works itself out and it is not small.

But the cost of paper is not only in the invoice. It is in the time lost searching. Workers spend on average around 1.8 hours per day — close to 9 hours per week — searching for and gathering information (McKinsey Global Institute, 2012). In a 50-person SME, that is many salaries a year spent chasing documents that ought to appear on a screen in two seconds.

Note what this figure conceals. It is not the 9 hours of a single person dedicated to the archive — that would be a conscious and measurable choice. It is 9 hours dispersed across dozens of people who do not have "searching for documents" in their job description: the production supervisor who halts the line to confirm a cutting sheet, the administrative assistant who trawls through email looking for an invoice PDF, the sales rep who calls the warehouse to find out whether the delivery note was signed. None of these minutes appears under a cost heading. They all add up.

The document that always disappears at the worst moment

There is a pattern that repeats across every sector we work with. The critical document is never missing under normal conditions. It is missing when the international customer asks for a certificate of origin in the middle of a factory visit, when the AT opens an inspection and asks for 24 months of SAF-T, when a supplier disputes a payment and the signed delivery note is in a drawer in Felgueiras that no one has opened for months.

In footwear, this is worse. A sample collection has between 800 and 1,200 SKUs, with technical sheets, cutting sheets, buyer orders and material certificates that accumulate with every campaign. International buyers visit twice a year — men's footwear in August, women's in February — and they expect impeccable and immediate documentation. Whoever presents a crumpled ring binder loses credibility before price is even discussed.

Portuguese footwear has, moreover, a weighty commercial argument: according to APICCAPS, Portugal is among the European countries with the highest average value per exported pair, which means it competes on quality and not on price. Now, whoever competes on quality cannot fail on documentation. A buyer from Central Europe visiting a factory in Felgueiras in August is assessing both the product and the factory's ability to respond, trace and prove. A tannery material certificate that does not appear in good time is a sign of disorganisation that contaminates the whole negotiation.

Textiles and the traceability that went from nice-to-have to obligation

In the textile industry of the Vale do Ave, the problem has an additional dimension that many companies have still not internalised. The EU Strategy for Sustainable and Circular Textiles, with the horizon of the Digital Product Passport foreseen within the Ecodesign for Sustainable Products Regulation, will require traceability information at batch and material level. Those who dye, finish and make up garments will have to prove the composition, origin and journey of each piece. This is not an environmental courtesy — it is a condition of access to the European market.

A finishing house in Vizela that cannot say today, in seconds, which dye entered which bath for which batch, is going to have a problem when the parent brand asks for the dyeing sheet of an order from two years ago. And it will ask. The large European brands have already begun conducting supply chain audits that go down to this level of detail. Documentary traceability has ceased to be a pretty binder to show at trade fairs — it has become the difference between keeping and losing a structural customer.

Who pays the invisible bill

The CFO sees the cost of paper under the stationery heading and thinks it is marginal. Wrong. The real cost is distributed across headings that no one connects: overtime at month-end close, penalties for invoices paid twice, prompt-payment discounts lost because the invoice sat three weeks on a desk awaiting approval, the IT time spent restoring folders deleted by mistake.

There is also a cost that rarely enters the calculation: the opportunity cost of cash flow. In an industrial SME, payment timing is an art of survival. An invoice forgotten on a desk can mean losing the 2% prompt-payment discount the supplier was offering — 2% on the raw-material purchasing volume of a textile company is real money. Or, on the other side, it can mean paying before the deadline out of sheer lack of visibility, draining cash flow that was needed for the close. Dispersed paper does not allow cash flow to be managed intelligently; it forces it to be managed in the dark.

Paper does not cost money in the place where we buy it. It costs where we look for it.

Month-end close at the garment factory — anatomy of a lost night

It is worth getting down to the concrete. In a garment factory in the municipality of Vila Nova de Famalicão, the month-end close is a well-known ritual. The administrative manager stays until nine or ten at night reconciling subcontracting invoices — because the garment factory subcontracts parts of production to other, smaller houses, and each issues its own invoice at its own pace and in its own format. Cross-checking those invoices against the work orders, confirming quantities, validating verbally agreed prices, finding the delivery note that proves the delivery: it is prospecting work.

When this work runs on paper and email, the quality of the close depends entirely on the memory and availability of one person. If that person is absent, falls ill or retires — as in the example we opened with — the company loses not a job, but a human database that no one documented. This is the most underestimated operational risk of Portuguese family industry: the critical knowledge is not in the system, it is in a head that is on its way to retirement.

What exactly is DL 28/2019 document management

First, a correction of vocabulary that avoids costly misunderstandings. "DL 28/2019 document management" is an expression that joins two distinct things that people confuse because they arrived on the market at the same time.

Decree-Law No. 28/2019 regulates the processing of invoices and other fiscally relevant documents. It establishes the rules for retention, the ATCUD (unique document code), the conditions for dematerialisation and the archiving obligations. It is not a law about generic document management — it is a law about fiscal documents. Document management (EDM, electronic document management) is the broader discipline: capturing, classifying, indexing, archiving, controlling access and defining the life cycle of any company document, fiscal or not.

The three technical pillars

A complete document management solution rests on three functions that work together:

• Cognitive capture — automatic reading of invoices, delivery notes, contracts and emails with field extraction (supplier, tax number, amount, dates, lines) without manual keying. Technologies such as Tungsten (formerly Kofax) do this with OCR and pattern recognition.
• Legal archive — a repository with evidential value, versioning, configurable retention and audit trail. Platforms such as DocuShare ensure that an archived document cannot be altered without a trace.
• Workflow and signature — approval circuits (who sees, who approves, who pays) and qualified electronic signature in accordance with eIDAS, with full legal validity.

What changes when capture is cognitive and not just OCR

There is a technical distinction that vendors rarely explain well. Basic OCR turns an image into text — it reads the characters. Cognitive capture goes further: it understands that the number next to the word "Total" is the invoice amount, that the set of nine digits is a tax number, that those repeated lines are items with quantity and price. It learns from corrections and improves with volume. The practical difference, for a textile company that receives invoices from 200 suppliers in 200 different layouts, is abyssal.

With simple OCR, each new layout is a configuration problem. With cognitive capture, the system generalises: it recognises the structure of an invoice even if it has never seen that specific supplier. It is this capability that makes it viable to automate the receipt of invoices in an SME with a heterogeneous supplier portfolio — which is the case for practically all Portuguese manufacturing industry.

A brief history of how we got here

Portugal began tightening the certification of invoicing software in 2010, with the requirement for programs certified by the AT. DL 28/2019 consolidated and modernised that edifice: it introduced the ATCUD, clarified the equivalence between paper and electronic invoices, and defined retention periods. The monthly communication of SAF-T (Ordinance 195/2020) closed the cycle. The result is that today, in fiscal matters, dematerialisation in Portugal is more advanced than the European average — but in operational document management, we remain behind.

It is a typically Portuguese paradox: the State pushed fiscal digitalisation with strong regulation and Portugal was, for years, a European case study for a digital tax control system. But that digitalisation stopped at the border of the tax authority. The invoice arrives in a certified format, is communicated by SAF-T — and is then printed and archived in a binder because the internal approval process still runs on paper. We modernised the relationship with the AT without modernising the company's relationship with its own documents.

The landscape in Portugal today

There is a paradox here worth exposing. In mandatory and certified invoicing, Portugal complies. In voluntary electronic invoicing and document automation, we drag our feet.

Electronic invoicing is still a minority practice among small European companies — around 37% in 2023 — far behind countries with generalised requirements such as Italy (97.4%) and Finland (92.9%), according to European Commission data (2024). Portugal is somewhere in the middle: it requires certification and SAF-T, but a large part of SMEs still exchange PDFs by email and print everything "to have to hand".

The European context is going to tighten. The VAT in the Digital Age (ViDA) initiative, approved at EU level, points to the generalisation of structured electronic invoicing and near real-time digital reporting on intra-community transactions over the course of the decade. For a deeply export-oriented Portuguese industry — textiles, clothing and footwear live off the foreign market — this means that the structured invoice will cease to be an option and become the norm in relationships with European customers and suppliers. Those who already have a digital document process arrive prepared; those who depend on the PDF by email will make the transition in a rush and under pressure.

What the numbers hide

The transition to electronic and automated invoicing reduces processing costs by 60% to 80% compared with paper, with a return on investment in 6 to 18 months (Billentis, 2025). It is not a brochure figure — it is an order of magnitude consistent with what we see on the ground. A company that processes 600 supplier invoices per month, at 13 dollars each, spends close to 94 thousand dollars a year on that process alone. Taking that cost down to 3 dollars frees up capital and administrative hours that no one had accounted for.

The return on document management does not come from selling more. It comes from ceasing to pay twice for the same document.

The productivity gap that Europe points out to us

It is worth framing this within a larger problem. Labour productivity in Portugal is persistently below the European Union average — it is one of the recurring themes in the analyses of the Banco de Portugal and the OECD on the Portuguese economy. One of the causes pointed to is the slow adoption of digital technologies by SMEs. Document management does not on its own solve the national productivity problem, but it is one of the cheapest and fastest levers to pull: it requires no investment in new machinery nor changing the product, it requires only ceasing to spend human hours on tasks that a system does in seconds.

Put another way: there are Portuguese industrial companies with state-of-the-art machinery on the factory floor and an administrative process from the 90s in the office next door. They invested well in productive productivity and nothing in administrative productivity. It is an imbalance that document management corrects with a comparatively small investment.

By sector, the pain has different colours

Distribution and the delivery dispute that is resolved with one click — or not

In distribution, the document that hurts is the proof of delivery. A warehouse in the Lousada/Paços de Ferreira corridor that dispatches hundreds of lines a day lives off signed delivery notes. When a customer disputes a delivery — "three boxes were missing", "it arrived broken", "I never received it" —, the only defence is the delivery note with the signature of whoever received it. If that delivery note is in a pile of paper waiting to be archived, or worse, if it was poorly scanned and the signature cannot be read, the company loses the dispute for lack of proof.

The warehouse manager knows this better than anyone. And that is why he is suspicious of any new system that forces more steps on him. The golden rule in distribution is not to take the manager off the radio for more than two hours at a stretch — because the warehouse does not stop for training. The document management that works in this context is the kind that captures the delivery note at the moment of delivery, on the terminal, without a subsequent administrative step. If it depends on someone scanning paper at the end of the day, it fails. This is where mobile capture, integrated with the warehouse operation, makes all the difference.

The implementation models

There is no single way to do this. There are four distinct approaches, with different costs, risks and maturities. Choosing the wrong one for the size of the company is the most common error and the most costly.

Model 1: Simple digital archive

Digitising documents and storing them in an organised folder structure, possibly with a basic indexing tool. Cheap, fast, and essentially useless beyond reducing physical space. There is no workflow, no automatic capture, no reinforced evidential validity. It is the minimum that a micro-enterprise does.

The dangerous error is to confuse this model with document management. A well-organised shared folder solves the problem of space in the office and nothing more. It does not reduce the cost per invoice, does not speed up approvals, does not protect against duplicate payments. It serves as a starting point for a micro-enterprise with very few documents, but anyone who has volume and treats this as a solution is merely deferring the problem with a digital cover.

Model 2: Standalone EDM

A dedicated document management platform (capture, archive, workflow, signature) that operates alongside the ERP but not integrated with it. Good for those with many non-transactional documents (contracts, HR, quality) and an ERP that is not going to change any time soon. The Achilles' heel is the double entry: the invoice enters the EDM and then someone re-enters it into the ERP.

This model makes sense in a specific scenario: companies with a strong component of quality and certification documentation — think of a mould-making unit with ISO 9001 and IATF managing hundreds of process sheets and control records — and whose ERP is untouchable in the short term by strategic decision. In those cases, a standalone EDM organises the non-fiscal document world and is worthwhile. But be honest about the double entry: if the bulk of your volume is supplier invoices, the standalone EDM solves the archive and leaves the manual entry problem intact.

Model 3: EDM integrated into the ERP

Document capture feeds directly into the ERP. The invoice is read, the fields are extracted, the document enters the approval circuit and, once approved, the accounting entry and the payment are pre-filled. This is where the 13 dollars per invoice fall to 3. It requires an ERP that accepts this integration — vertical industrial ERPs do it natively.

For the overwhelming majority of medium-sized Portuguese manufacturing industry, this is the right model. The reason is simple: the document that hurts most is the supplier invoice, and the supplier invoice is a transactional document that has to end up in the ERP anyway. Integrating capture with the ERP eliminates the one step that the standalone EDM retains — the re-entry. It is the difference between automating half the process and automating the whole process.

Model 4: Enterprise content management platform (ECM)

The top of the pyramid: management of all enterprise content, with predictive analytics on documents, automatic retention policies, and cross-cutting compliance (fiscal, GDPR, quality, security). It makes sense for groups with several companies, subsidiaries and high volumes. It requires integration between subsidiaries and a thought-through architecture.

A textile group with spinning, weaving and garment-making in legally distinct but jointly managed companies is the natural candidate for ECM. The advantage is not only volume — it is consistency. When the same document (a material sheet, a certificate, a retention policy) has to hold good across three companies, managing this in separate silos multiplies the error. ECM imposes a single, cross-cutting policy. The cost and complexity are real and should not be underestimated, but for groups of this profile the return is also cross-cutting.

How to assess whether your company needs it

Before looking at vendors, do the honest diagnosis. Most companies discover that they need model 3 but go around buying model 1 out of fear of the investment.

Signs that you have already lost money this month

• Someone at month-end close stays late chasing invoices and delivery notes in shared folders.
• You have already paid an invoice twice in the last 12 months (it happened more often than you admit).
• You lost prompt-payment discounts because approval took too long.
• A customer or AT audit forced a days-long scramble to gather documents.
• The knowledge of "where things are" resides in the head of one or two people.
• You digitise documents but then re-enter the data manually into the ERP.

The bus test

There is a brutal test I use in meetings with the boards of family SMEs. I ask: if the person who handles the administrative documents were run over by a bus today — forgive the macabre — how long would it take the company to function normally? If the answer is "weeks" or "I don't know", the company does not have an efficiency problem, it has a business continuity problem. The critical knowledge is in a head and not in a system.

Document management solves this not because it replaces the person, but because it documents the process. When the approval circuit is in the system, when the documents are indexed and searchable, when the history is recorded with an audit trail, the departure of a person ceases to be a catastrophe and becomes a manageable transition. For a family company where turnover is low and the key people have been there for decades, this risk seems abstract — until the day when retirement, illness or departure happens.

Step by step

Do this diagnosis before speaking to any vendor. It takes half a day and avoids buying the wrong solution.

1. Count the documents. Survey the number of supplier invoices, delivery notes, contracts and quality documents that come in per month. Without this number, any decision is a guess.
2. Time the current process. Measure how long passes between the invoice arriving and being paid, and how many hands it passes through. Go to the Gemba — the place where the work happens — and observe, do not ask.
3. Calculate the hidden cost. Multiply the monthly volume by a realistic unit cost of manual processing and add the penalties from the last year (duplicate payments, lost discounts, overtime).
4. Map the legal obligations. Check what DL 28/2019, GDPR and your customers' audits require in terms of retention, traceability and access.
5. Define the target scenario. With the numbers in hand, decide which model (of the four above) solves the real problem — and not the problem that is comfortable to solve.

Whoever does not measure the cost of paper will always think the solution is expensive. It is the paper that is expensive; it just did not come with an invoice.

What to choose and why

The right decision depends almost entirely on the size and document profile. Here is the matrix we use to guide it.

The classic error of the decision trio

Portuguese family companies decide in a trio: CEO, CFO and the IT manager. The latter is often a self-taught hero with 15 years of business knowledge and no formal diploma — and it is he who carries the operation on his back. The classic error is the CFO wanting the cheapest model, the CEO wanting to "solve everything at once" with the most expensive model, and IT knowing which is the right one but having no numerical arguments to defend it in the meeting.

The solution is to arrive at the meeting with the hidden cost calculated. When IT says "we spend X thousand euros a year on manual invoice processing", the conversation changes tone. Automation ceases to be an expense and becomes the elimination of an expense that already exists.

The financing that changes the maths — if you know how to use it

There is one piece that the decision trio frequently ignores: financing. The instruments of PT2030 — COMPETE 2030, Norte 2030 — and of the PRR include support lines for the digital transition of SMEs, and document dematerialisation fits naturally within the objectives of process digitalisation. I will not promise that the application is easy or that the approval rate is generous — what we see on the ground is that projects with a well-built business case and clear metrics fare better in the technical reports, and vague projects get stuck.

The practical implication for the decision trio: a well-prepared document management project, with the hidden cost quantified and the productivity gains estimated, not only defends itself internally but also applies better for support. IAPMEI and the CCDRs assess substance. Arriving with "we want to digitalise" is weak; arriving with "we process 700 invoices/month at a unit cost of X and project a reduction of Y with a return in Z months" is an argument both for the board and for the application evaluator.

Beware of capture without workflow

An operational detail that the manuals do not mention: buying cognitive capture without redesigning the approval circuit is halfway to failure. The technology reads the invoice in seconds, but if it then sits awaiting approval in an inbox that the director only checks on Fridays, you have gained nothing. Document automation is 40% technology and 60% redesigning who approves what and in how long.

This is the point where most projects stumble. The technology delivers — capture works, archive works, signature works. But if the company keeps the human bottleneck of the single approver who has to see everything, the invoice continues to sit stalled, now in a system instead of on a desk. The real gain comes from redesigning the circuit: setting value thresholds above which approval escalates a level, delegating routine approvals, establishing deadlines and automatic alerts. The technology is the means; the governance of the process is the end.

Regulatory framework and applicable compliance

Document management in Portuguese industry crosses several regimes that are rarely thought about together. Ignoring any one of them creates risk.

• DL 28/2019 — rules on invoicing, ATCUD, retention and dematerialisation of fiscal documents. The basis of everything.
• Ordinance 195/2020 — monthly communication of SAF-T to the Tax Authority.
• GDPR + Law 58/2019 — protection of personal data in HR, customer and supplier documents. Retention is not infinite: keeping everything "just in case" violates the principle of minimisation.
• eIDAS (EU Reg. 910/2014) — qualified electronic signature with full legal validity, essential for dematerialising contracts and approvals.
• NIS2 (EU Directive 2022/2555 + DL 65/2025) — cybersecurity of essential and important entities. A document repository is critical information infrastructure.
• ISO 27001 — information security management, increasingly required by international customers as a prerequisite.

There is a tension here that few anticipate: GDPR requires personal data to be erased when it is no longer needed, but DL 28/2019 requires the retention of fiscal documents for years. The resolution lies in retention policies configurable by document type — an invoice is retained; the CV of an unsuccessful candidate is erased. A shared-folder archive cannot tell the difference. A document management platform can.

Keeping everything forever is not prudence. After GDPR, it is a breach waiting to happen.

The whistleblowing channel and the archive it requires

A regime that rarely enters the document management conversation, but should: Law 93/2021 obliges companies with 50 or more staff to have an internal whistleblowing channel. Now, a report generates documents — the record of the communication, the handling process, the decisions — which have to be kept with reinforced confidentiality and strict access control, because sensitive data and the protection of the whistleblower are at stake. Managing this in email or a shared folder is a breach waiting to happen.

It is a perfect example of how regulatory compliance and document management are the same discipline seen from different angles. The law creates an obligation; the obligation generates documents; the documents need secure archiving, controlled retention and restricted access. Without a platform that knows how to handle different types of document with different rules, the company complies with the law on paper and fails it in practice.

The cybersecurity dimension that no one connects to EDM

A document repository concentrates everything the company holds sensitive: contracts, customer data, intellectual property, product technical sheets. With NIS2 expanding the perimeter of covered entities and the legacy of disciplines such as DORA in the financial sector, the resilience of the digital archive has ceased to be an extra. A repository without access control, without an audit trail and without tested backup is a compliance risk and a target. The security of the repository is part of the decision, it is not a later accessory.

ENISA has repeatedly warned of the increase in ransomware attacks aimed at European SMEs — precisely because they are the weakest and least protected link in the chain. For a mould-making factory in Marinha Grande, the technical drawings and process sheets are the most valuable asset that exists; an attack that encrypts or exposes them is potentially fatal to the business. Concentrating these documents in a repository with profile-based access control, versioning and tested backup is not just good document management — it is existential risk management. The question is not whether it is worth protecting; it is whether the company survives not protecting.

How INFOS approaches this

We have been working with Portuguese industry for 36 years and our approach to document management starts from one principle: the right document has to appear on the screen of whoever is working, when they are working, without leaving the system where it already is. That is why our Document Management solution combines cognitive capture (Tungsten), legal archive (DocuShare), approval workflow and qualified eIDAS signature — and connects to the ERP, it does not live alongside it.

In practice, this means that a supplier invoice is read, the fields extracted, the document follows the defined approval circuit, and the entry in the MULTI ERP arrives pre-filled. For those who want to see the effect on cost and close time, Qlik Sense shows the indicators in dashboards instead of monthly spreadsheets. And for people documents — contracts, attendance, appraisals — pplPortal integrates the HR document component into the same compliance effort.

We do not sell the digitisation of folders. We sell the elimination of the work of searching. The difference is noticeable after a quarter, in the month-end close that no longer demands late nights.

Why we insist on integration with the ERP

The market's temptation is to sell a pretty, standalone EDM that impresses in the demo. We resist that temptation out of experience. The EDM that impresses in the demo but forces the invoice to be re-entered into the ERP does not survive the month-end close test: the administrative assistant, under pressure, reverts to the old shortcut and the expensive platform becomes an expensive archive. We have seen this happen in projects that were not ours, and we have learned from those cases.

Integration is not a technical detail — it is the condition of the project's survival. When the captured document feeds directly into the ERP entry, the step where the old process stubbornly returned is eliminated. This is the most important operational lesson we have to share about document management in industry: the solution has to eliminate work, not add a parallel system where there was once paper.

Failures that taught us

We would be dishonest if we said that every project went smoothly. We learned, for example, that underestimating the resistance of the operational floor is the error that most delays a rollout. In a warehouse capture project, the pilot technically worked, but the operators got around it because it had one step too many on the terminal and no one had involved them in the design. We corrected it by reducing the step and bringing the warehouse manager to the decision table from the start. The lesson stuck: the right technology with the wrong human process fails just the same.

We also learned that phasing is not slowness — it is risk management. Trying to dematerialise everything at once in an SME overloads the administrative team, which is already at its limit. Starting with the supplier invoice cycle, proving the return, building confidence, and only then expanding, is the path that least often derails. That is why we structure projects in phases with verifiable milestones, as described below.

30/60/90-day roadmap

A document management project is not done in a big bang. It is done in phases, with verifiable milestones, and without taking the warehouse manager off the radio for more than two hours at a stretch — because he will fight against any rollout that does so.

Days 1-30: measure and design

• Survey the real document volume by type (invoices, delivery notes, contracts, quality) and calculate the current hidden cost.
• Map the existing approval circuits — who sees, who approves, how long each step takes.
• Identify the applicable legal obligations (DL 28/2019, GDPR, customer audits) and define retention policies by document type.
• Define the target model (of the four) and the scope of the first phase — normally the supplier invoice cycle, where the return is fastest and most visible.

Days 31-60: controlled pilot

• Configure cognitive capture for a subset of high-volume suppliers — the 20% that generate 80% of the invoices.
• Implement the approval workflow for that subset, with deadlines and alerts.
• Train the administrative team and the approvers, without stopping the operation — the pilot runs in parallel with the old process for a few weeks.
• Measure the before/after in processing time and in the number of hands per document.

Days 61-90: expand and consolidate

• Extend capture to the full universe of suppliers and add delivery notes and other transactional documents.
• Integrate the qualified electronic signature into the circuits for contracts and approvals.
• Activate the monitoring dashboards and define the management indicators (cycle time, cost per invoice, on-time approval rate).
• Review the retention policies and access controls in light of what the pilot revealed.

The indicators that prove it was worth it

A project without success metrics is faith, not management. Before starting, define the numbers you will compare at the end. The ones we use most are the invoice cycle time (from receipt to payment), the cost per invoice processed, the percentage of invoices approved within the deadline, the number of duplicate payments (which should tend to zero) and the response time to an audit request (from days to minutes). These indicators fit on a dashboard and tell the story better than any report.

After 90 days, the objective is not to have everything dematerialised. It is to have the process that hurts most — the invoice cycle — running digitally, with the cost per document measured and falling, and the team trusting the system. The rest follows by knock-on effect, because whoever has seen the month-end close shorten does not go back to the ring binder. To design the following phases without stopping the operation, it is worth understanding where to start with document process automation and how to comply with DL 28/2019 without paralysing operations.

The question that remains is not whether your company is going to dematerialise. It is how many month-end closes you are still willing to pay for in overtime before doing so.

Sources

• Decree-Law No. 28/2019 — Diário da República (regime for the processing and retention of invoices and fiscally relevant documents).
• Ordinance No. 195/2020 — Diário da República (communication of SAF-T to the Tax Authority).
• Law No. 93/2021 — Diário da República (whistleblower protection regime; internal whistleblowing channel).
• Regulation (EU) No. 910/2014 (eIDAS) — qualified electronic signature.
• Directive (EU) 2022/2555 (NIS2) — cybersecurity of essential and important entities.
• Regulation (EU) 2016/679 (GDPR) and Law No. 58/2019 — protection of personal data.
• European Commission (2024) — data on the adoption of electronic invoicing in the EU; VAT in the Digital Age (ViDA) initiative.
• Ardent Partners / IOFM (2022) — average cost of processing invoices.
• Billentis (2025) — cost reduction and return on investment in electronic invoicing.
• McKinsey Global Institute (2012) — time spent by workers searching for information.
• INE — Portuguese business structure (predominance of micro and small enterprises).
• Banco de Portugal / OECD — analyses of productivity and digital adoption of SMEs in Portugal.
• APICCAPS — indicators of the Portuguese footwear sector.
• ENISA — reports on the cybersecurity threat landscape in the EU.

Frequently asked questions

Does DL 28/2019 require the implementation of a document management system?

No. DL 28/2019 requires only the certification of electronic invoicing (SAF-T). True document management — archiving, traceability, organisation — remains optional. However, the EU's traceability requirements and sustainability audits make it increasingly necessary in order to compete.

How much does it cost to process an invoice manually versus automated?

Processing manually costs around 13 dollars per invoice. Automation reduces it to approximately 3 dollars. A medium-sized textile factory receiving 400 to 800 invoices monthly can save tens of thousands of euros a year with document automation.

What is the true hidden cost of documentary disorganisation?

It is not just the paper. Staff lose on average 1.8 hours daily searching for information — around 9 hours weekly dispersed across several departments. In a 50-person SME, this represents several annual salaries spent locating documents that should be accessible in seconds.

Why can Portuguese footwear not fail on documentation?

Portugal competes in footwear on quality, not on price. International buyers assess both the product and the capacity for traceability and documentary proof. A material certificate that does not appear in good time signals disorganisation and compromises high-value commercial negotiations.

What is the Digital Product Passport and how does it affect textiles?

It is an EU regulation that will require traceability at batch and material level for textile products. Dyeing, finishing and garment-making companies will have to prove the composition, origin and journey of each piece. This has ceased to be optional — it is a condition of access to the European market.

How does the lack of documentary traceability affect sustainability audits?

International brands conduct supply chain audits that require detailed information on old batches. Without an organised document system, responding takes days and involves informal contacts. This compromises the commercial relationship and the company's credibility.

Where do the invisible costs of documentary disorganisation hide?

They are distributed across unrelated headings: overtime at month-end close, invoices paid twice, prompt-payment discounts lost due to approval delays, and IT time restoring deleted folders. None appears in isolation, but the total is significant.