Norway Finalises B2B E-Invoicing Rules for 2027, Including Formats, Exemptions and Transition Period

Norway has finalized its B2B E-Invoicing rules ahead of January 1, 2027, confirming approved invoice formats, exemptions and transitional arrangements. Mandatory E-Invoice reception and digital bookkeeping will follow in 2030, giving businesses additional time to adapt their systems.

Norway has finalized the implementing regulations for its mandatory Business-to-Business (B2B) e-Invoicing framework, confirming the technical standards, exemptions and transitional arrangements that businesses must consider before January 1, 2027.

On September 29, 2026, the Norwegian Tax Directorate adopted amendments to the Bookkeeping Regulation, following amendments to the Bookkeeping Act adopted in June 2026. The Tax Authority published an official explanation on September 30.

The regulations clarify that businesses subject to Norwegian bookkeeping obligations must generally issue structured electronic invoices when selling goods or services to other bookkeeping-obligated businesses from January 2027.

However, the obligation to receive e-Invoices will not become mandatory until January 1, 2030. Until then, the practical obligation to issue an e-Invoice depends on whether the business customer can receive one.

The framework also introduces additional requirements concerning invoice content, electronic accessibility of records and digital bookkeeping, with different implementation dates.

Norway has established a phased implementation schedule rather than requiring all businesses to change their invoicing and accounting systems simultaneously.

The confirmed implementation dates are:

• January 1, 2027: Mandatory issuance of structured e-Invoices for applicable B2B transactions. The existing exemption from electronic accessibility requirements for businesses with turnover below NOK 5 million is also withdrawn.
• January 1, 2028: The buyer's organization number must be included in sales documents issued to bookkeeping-obligated buyers. Businesses can no longer agree to withhold all or part of a sales document from such buyers.
• January 1, 2030: Mandatory capability to receive structured e-Invoices and the general requirement to maintain bookkeeping records using a digital accounting system, subject to applicable exemptions.
• The 2027 sending obligation and the 2030 receiving obligation are established under Section 10 of the Bookkeeping Act. The mandatory use of a digital bookkeeping system follows Section 7.

Importantly, these requirements concern sales between businesses subject to Norwegian bookkeeping obligations. They do not introduce a general e-Invoicing requirement for ordinary Business-to-Consumer (B2C) retail sales.

The amended Bookkeeping Regulation, Section 5-2-9, specifies the approved electronic invoice standards applicable from January 1, 2027.

These are:

• EHF Invoicing 3.0 or later,
• Peppol BIS Billing 3.0 or later,
• EHF Self-Billing 3.0 or later,
• Peppol BIS Self-Billing 3.0 or later.
• The regulations also provide a transitional arrangement allowing businesses to continue using other structured electronic invoice formats until January 1, 2030.

Examples include EDIFACT and E2B, provided the formats satisfy the legal definition of an electronic invoice.

Under Section 3 of the Bookkeeping Act, an electronic invoice must be a sales document that can be issued, sent and received in a structured electronic format suitable for automated processing in an accounting system.

Consequently, a PDF invoice does not qualify as a structured e-Invoice.

Where a bookkeeping-obligated buyer can receive a compliant e-Invoice, sending only a PDF will not satisfy the new issuance requirement.

This distinction matters for businesses currently generating invoices as PDF documents through their POS, ERP or accounting software.

One of the most important clarifications concerns the different starting dates for issuing and receiving E-Invoices.

Although the issuance obligation begins in 2027, buyers are not generally required to have electronic invoice reception capabilities until 2030.

The Norwegian Tax Authority therefore confirms that, during the transition period, the obligation to issue E-Invoices will in practice apply where the buyer can receive them, typically through registration in ELMA, Norway's electronic recipient register connected with Peppol.

Where the buyer does not yet have the required receiving functionality, the transitional arrangements limit the practical application of the sending obligation.

From January 2030, the general receiving obligation will remove this transitional limitation for businesses within scope.

The regulations establish specific exemptions for certain businesses and activities.

Businesses with annual turnover not exceeding NOK 50,000 may qualify for exemptions from digital bookkeeping and E-Invoice reception requirements, subject to the conditions in Section 1-2 of the Bookkeeping Regulation.

However, an eligible small business using an invoicing system capable of issuing e-Invoices may still be required to use that functionality.

Other exemptions cover certain bankruptcy estates, financial activities, insurance companies and pension undertakings.

Separately, from January 2027, Norway removes the existing exemption from electronic accessibility requirements for bookkeeping-obligated businesses with turnover below NOK 5 million.

This requirement should not be confused with the broader obligation to use a digital bookkeeping system, which generally begins in 2030.

Electronic invoices must also be retained in their original electronic format for the applicable statutory retention period.

Impact on retailers and POS providers

For retailers, the main impact concerns B2B transactions where a business customer receives an invoice.

Where invoices are generated through an ERP or dedicated invoicing application, businesses should ensure that these systems support the required structured formats and transmission procedures.

If the POS system itself generates B2B invoices, the retailer and software provider should assess whether that functionality can meet the applicable e-Invoicing requirements or whether invoice generation should be handled through an integrated ERP or invoicing solution.

From our perspective, the most important implementation issue is the distinction between invoice issuance and reception obligations. The transition period provides additional flexibility, but it does not create a general postponement of mandatory B2B e-Invoice issuance until 2030.

What should businesses prepare?

Businesses subject to Norwegian bookkeeping obligations should review their B2B invoicing processes before January 1, 2027.

They should confirm whether their invoicing systems support EHF, Peppol BIS or another format permitted during the transition period, and establish procedures for identifying business customers capable of receiving structured E-Invoices.

Retailers should also determine whether B2B invoices are generated through their POS, ERP or another system and verify which solution will handle compliant electronic invoice issuance.

Preparation should additionally cover the buyer organization number requirement from 2028, applicable document-retention obligations and the digital bookkeeping and E-Invoice reception requirements beginning in 2030.

The principal legal basis is the Bookkeeping Regulation, amended by the Norwegian Tax Authority on September 29, 2026. Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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