Letter from the table: What my invoice record shows

RC/CF/2026/T.21
Date: 14 March 2026
Stance: Amend

To the Cashflow Council

I keep a record of invoices, reminders and payments because memory is not good enough when a bill is late. The record is ordinary: invoice date, amount, agreed due date, the days between that date and payment. It does not tell the whole story, but it does show what waiting costs a small business that has already done its work.

One invoice was for €2,760. I issued it on 6 October 2025, after completing the agreed work. The invoice set a due date of 5 November. The client was a larger organisation; I will not name it. The amount was not in dispute, and I had no indication that the invoice was incomplete or had gone to the wrong place.

On 5 November, the due date passed. I followed up on 14 November, then again on 1 December. I resent the invoice and asked whether anything was needed from me to release payment. I kept the messages brief and polite. I did not threaten legal action or add interest. Payment arrived on 18 December: 43 days after the due date.

Forty-three days is easy to write down and harder to absorb. The money was already committed in my plans—to cover business costs and my own obligations. I moved payments around and put off other spending. I also spent time checking the account, preparing reminders and wondering whether another follow-up would help or make the relationship harder. That time did not appear on the invoice.

Portugal already has a framework for late payment in commercial transactions. Decree-Law no. 62/2013 provides for statutory late-payment interest and a fixed minimum compensation of €40 for recovery costs. In business-to-business transactions, the usual payment period is 30 days; parties can agree longer terms, generally up to 60

days, subject to the law’s protections against unfair terms. Those rights matter. But having a right on paper is not the same as being able to use it without spending more time, risking a relationship or wondering whether the next piece of work will disappear.

That is why I support the direction of CF-001. A 15-day expectation for large buyers would be a meaningful improvement on waiting beyond a 30-day term, and automatic interest would make the consequence of delay less dependent on each supplier’s willingness to argue. Publishing payment times could also make the pattern visible instead of leaving each small supplier to manage it privately.

My stance is amend, not reject. The standard needs a precise starting point. I would make the 15 days run from receipt of a compliant invoice for work or goods already accepted. If a buyer disputes part of an invoice, it should identify the specific disputed amount and reason promptly; the undisputed portion should still be paid on time. Otherwise, a vague query—or a late request for information—could restart the clock for the whole invoice. The standard should also say whether the 15 days are calendar days, and require buyers to make the payment-time information comparable, rather than leaving each one to report in a different way.

I would keep the interest provision, but make the practical route clear. A supplier should be able to see how interest is calculated, and claiming it should not require a fresh negotiation with the buyer. A buyer should not be able to make prompt payment conditional on a supplier waiving interest or recovery costs. At the same time, the standard should not ask a small supplier to pursue a complex claim over every late invoice before the standard counts as meaningful.

There is a reason to be careful about the dispute rule. Work can require review, and genuine errors happen. I am not asking the Council to treat every query as bad faith. I am asking it to distinguish a specific, timely dispute from silence. In my episode, I spent weeks following up without a clear issue being raised. A rule that records the date an invoice is received, requires a prompt explanation of any dispute, and protects the undisputed amount would address that kind of delay without pretending every invoice is simple.

Notes and sources

1. As of 14 March 2026, the Cashflow Council had received 107 reports from 34 countries. ↩