Mandatory Electronic Invoicing in New Zealand

New Zealand’s model emphasizes voluntary uptake with government leadership on Peppol for domestic B2G transactions. Large suppliers face mandatory requirements from 2027 for government work, while the broader economy benefits from efficiency gains without immediate mandates or real-time tax reporting. Businesses should prepare systems for Peppol compatibility and maintain 7-year records. Monitor official channels for potential future expansions.

New Zealand is implementing e-invoicing progressively, led by government procurement, while keeping it voluntary for the wider B2B and B2C sectors. The approach uses the Peppol framework for standardized electronic invoice exchange (XML via Peppol BIS Billing 3.0 with PINT A-NZ format). No broad legal mandate exists yet for all businesses, but specific rules apply to government agencies and large suppliers.

Main Themes

• Phased Government-Led Rollout: Focuses on domestic invoices and large entities, with key dates in 2026–2027. The goal is to encourage broader voluntary adoption across the economy.
• Voluntary for B2B/B2C: Businesses can continue using paper or PDF invoices.
• Mandatory B2G for Large Suppliers (1 Jan 2027): Government agencies must require “large” suppliers (annual revenue > NZ$33 million in each of the last two years, per Financial Reporting Act 2013, Section 45) to send e-invoices. Enforced via procurement rules (Rule 44).
• Peppol Standard: Businesses connect via accredited access points using their NZBN as the identifier. Applies to domestic trade invoices (NZD-priced supplies within New Zealand).
• No Real-Time Reporting: E-invoicing is B2B exchange on the Peppol network; invoices are not automatically sent to Inland Revenue. GST is reported via periodic returns.
• Commercial Incentive: Non-compliance by large suppliers may reduce competitiveness in future government tenders.
• Archiving: All invoices and related records must be retained for at least 7 years in a secure, accessible electronic or paper form.

Implementation Timeline

• 31 Mar 2022: All central government agencies required to receive e-invoices.
• 1 Dec 2025: 5th Edition of Government Procurement Rules takes effect, adding e-invoicing requirements.
• 1 Jan 2026: High-volume government agencies (>2,000 domestic invoices/year) must be e-invoice capable. Agencies must process most invoices electronically and pay 95% of domestic e-invoices within 5 business days.
• 1 Jan 2027: Mandatory e-invoicing for large suppliers to government. Short grace period allowed for transition; extended non-compliance affects future contracts.

Scope:

• In Scope: Domestic B2G trade invoices.
• Out of Scope: Cross-border transactions, foreign suppliers without NZ presence, employee expenses, utility/lease payments, credit card/insurance payments, and non-invoice payment schedules.
• B2B/B2C: Remains voluntary (over 50,000 organizations registered voluntarily as of 2025).

Data Requirements for E-Invoices

E-invoices (and all invoices) must include taxable supply information for GST (updated rules effective 1 Apr 2023):

• Supplier: name, address, GST number (NZBN often used).
• Customer: name, address, GST number/NZBN (if applicable).
• Invoice details: date, unique number, payment due date.
• Line items: description, quantities, unit prices.
• Tax/totals: total payable, GST amount/breakdown (15% rate, inclusive/exclusive), currency (usually NZD), plus references (e.g., PO numbers).

Peppol e-invoices in PINT A-NZ format automatically meet these structured requirements.

Transmission, Reporting & Compliance

• No real-time e-reporting or clearance system. GST returns remain periodic (monthly, bi-monthly, or six-monthly) and are self-prepared; no pre-filled returns from Inland Revenue.
• Prompt payment incentive: Faster processing for e-invoices.
• Penalties: No direct fines for non-e-invoicing outside procurement. Commercial consequences for government contracts. Standard GST penalties apply for record-keeping failures or missing taxable supply information.

Archiving & Storage

• 7-year minimum retention for all invoices and supporting documents.
• Electronic storage is permitted if secure, integral, readily accessible, and convertible to English for audits. Original XML files recommended.

Pre-Filled GST Returns

None currently. Businesses compile returns from their own records. No announced plans to use Peppol data for auto-filling.

Official Resources

• Government Procurement Rules (5th Edition, Rule 44) – procurement.govt.nz
• Official NZ eInvoicing website (MBIE) – einvoicing.govt.nz
• Inland Revenue: Taxable supply information & eInvoicing guidance – ird.govt.nz
• Financial Reporting Act 2013, Section 45