Regulatory updates - Norway

The amendment and the following statement from the Norwegian Tax Directorate clarify that the following e-invoicing obligations will apply:

• January 1, 2027: Entities subject to bookkeeping obligations shall issue electronic invoices when selling goods and services to other entities subject to bookkeeping obligations
• Transitional period between January 1, 2027 until January 1, 2030: The obligation to issue electronic invoices will in practice only apply when the recipient subject to bookkeeping obligations has the functionality to receive such invoices (registered in ELMA/Peppol)
• January 1, 2030: The obligation to receive electronic invoices for entities subject to bookkeeping obligations is introduced

Format requirements and transitional rules

The amendment clarifies that starting January 1, 2027, approved standards for electronic invoices are EHF Invoicing, Peppol BIS Billing, EHF Self-Billing and Peppol BIS Self-Billing, each in version 3.0 or later.

The Directorate furthermore underlines that during the transition period from January 1, 2027 to January 1, 2030, it is permitted to use other electronic invoice formats than those mentioned above, if they fulfill the Act’s electronic invoice definition, i.e. sales documents that can be issued, sent and received in a structured, electronic format, suitable for automated processing in the accounting system. Examples include EDIFACT and E2B.

The Directorate however emphasizes that invoices in PDF format do not have these properties and cannot be used if the buyer who is required to keep records can receive electronic invoices.

Bookkeeping and digital bookkeeping requirements

The amendments furthermore define the following timelines introducing various requirements related to bookkeeping:

• January 1, 2030: Bookkeeping must be carried out in a digital bookkeeping system for businesses subject to bookkeeping obligations, unless the ministry has determined otherwise in regulations or individual decisions
• January 1, 2028: The buyer’s organization number must always be provided on the sales document provided the buyer is a bookkeeping obligated business. Furthermore, it will no longer be allowed, in transactions with bookkeeping obligated buyers, to agree between the parties that all or part of the sales document shall not be sent
• January 1, 2027: The current exemption for bookkeeping obligated businesses with turnovers below 5 million NOK (approximately 460,000 EUR) from the requirement to keep booked information electronically accessible is repealed. Separately, electronic invoices must be retained in their electronic format throughout the applicable retention period

Exemptions

The exemptions differ between the obligations to issue and receive e-invoices and the requirement to use a digital bookkeeping system:

• Businesses with low turnover (not exceeding 50,000 NOK): Bookkeeping obligated businesses meeting the conditions in section 1-2 of the Bookkeeping Regulation are exempt from the requirement to use a digital bookkeeping system. They are also exempt from the requirement to receive electronic invoices. However, the exemption from the requirement to issue electronic invoices does not apply where sales documentation is issued through an invoicing system that supports electronic invoicing. In such cases, the sales documentation must be issued in an electronic invoice format. If turnover exceeds NOK 50,000 (approximately 4,600 EUR) during the calendar year, the exemption ceases to apply when the threshold is exceeded.

In addition, exemptions apply to certain sector-specific sales documentation relating to financial activities, insurance companies and pension funds. Separate exemptions apply to certain bankruptcy estates.

The approved changes are set to be rolled out in two phases:

• January 1, 2027: All bookkeeping-obligated businesses must send e-invoices to other businesses registered in the Electronic Recipient Register (ELMA)
• January 1, 2030: All businesses must also be able to receive e-invoices and conduct bookkeeping in a qualifying digital accounting system

Under the new rules, PDF and paper invoices will no longer qualify as valid invoices for B2B transactions, and spreadsheets or word processors will no longer be acceptable bookkeeping tools. The obligation applies to all transactions between bookkeeping-obligated businesses and does not cover sales to consumers or cash sales.

Exemptions are planned for businesses with annual turnover below NOK 50.000 (approximately 4.500 EUR), certain bankruptcy estates, financial enterprises, banks, insurance companies and pension funds.

Implementation details, such as format requirements, are expected to be published at a later stage.

The Act enters into force from the time determined by the King. The King may bring individual provisions into force at different times.

The proposal sets out the following timeline:

• Requirement to send electronic invoices: January 1, 2027
• Requirement to use a digital bookkeeping system that, among other things, receives and processes e-invoices automatically: January 1, 2030

In a follow-up letter, dated March 16, 2026, the Ministry of Finance has asked the Directorate of Taxes (Skattedirektoratet) to prepare the necessary regulatory amendments, including more detailed rules on invoice format, electronic bookkeeping systems, and possible exemptions or postponements for small businesses.

The Directorate is also asked to assess whether similar requirements should be extended to other areas, such as consumer invoicing (B2C), e-receipts, and possible regulation of accounting system providers.

Among the proposals previously discussed are making EHF (Elektronisk Handelsformat) the mandatory e-invoicing format and exempting businesses with turnover below 50,000 NOK (approximately 4,500 EUR) that are not required to keep accounts or submit VAT returns.

 The Directorate's broader review is due by December 15, 2026, and relevant stakeholders are to be involved in the process.