No, most businesses will not automatically be ready for the Norwegian electronic invoicing requirement (e-invoicing, typically EHF) that enters into force on 1 January 2027. Compliance will require active adjustments to invoicing systems, internal procedures and agreements with customers and suppliers. The requirement also applies to foreign-owned businesses in Norway conducting B2B transactions, including Norwegian subsidiaries and branches (NUF) of foreign companies, as well as other foreign businesses that are subject to Norwegian bookkeeping requirements.
In this article, we outline the key dates, the requirements for approved formats, the applicable exemptions and the circumstances in which businesses may apply for an exemption.
The changes also raise important issues relating to internal controls, VAT treatment, data quality and system architecture.
1 January 2027 – obligation to issue electronic invoices: From 1 January 2027, entities subject to statutory bookkeeping requirements must issue electronic invoices when selling goods and services to other entities subject to such requirements. Until the obligation to receive electronic invoices is introduced in 2030, the requirement will, in practice, apply where the recipient has the functionality required to receive electronic invoices, typically through registration in the Peppol register (formerly ELMA).
1 January 2028 – requirement to include the purchaser’s organisation number: From 1 January 2028, the purchaser’s organisation number must be stated in the sales documentation when invoicing purchasers that are subject to statutory bookkeeping requirements. This represents a tightening of the current rules.
1 January 2030 – obligation to receive electronic invoices and use an electronic accounting system: From 1 January 2030, businesses will be required to receive electronic invoices. At the same time, bookkeeping must be carried out using an electronic accounting system, unless an exemption applies under regulations or pursuant to an individual decision, as further described below.
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EHF (Elektronisk Handelsformat) is the Norwegian standard format for electronic invoices and credit notes. An EHF invoice is a structured XML file, not a PDF, which is sent through the Peppol network and can be read and processed automatically by the recipient’s accounting system. EHF is based on the European standard EN 16931 and the international Peppol BIS Billing 3.0 specification, and it has been mandatory for invoicing the Norwegian public sector since 2019.
For international businesses, this means that an invoicing solution already supporting Peppol BIS Billing 3.0, for example one used in other European countries, will in many cases also be suitable in Norway. The business must, however, ensure that it is able to send and receive invoices via a Peppol access point.
The Norwegian Bookkeeping Act defines an electronic invoice as a sales document that can be issued, transmitted and received in a structured electronic format suitable for automated processing in an accounting system.
From 2027, the following formats will constitute approved standards:
EHF Invoicing
Peppol BIS Billing
EHF Self-Billing
Peppol BIS Self-Billing
All formats must be version 3.0 or later.
Importantly, a PDF invoice sent by email does not qualify as an electronic invoice under the bookkeeping legislation. Accordingly, where the recipient is able to receive electronic invoices, a PDF invoice will not be sufficient.
To facilitate the transition, a transitional period has been established until 1 January 2030.
During this period, businesses may continue to use structured electronic invoice formats other than EHF and Peppol BIS, provided that the relevant format meets the definition of an electronic invoice under the Norwegian Bookkeeping Act, such as EDIFACT and E2B. The use of such formats does not require an application to the tax office.
The transitional rule does not apply to PDF invoices. A PDF is not considered a structured electronic format and is therefore not covered by the transitional arrangement.
Some businesses are permanent exempted from the electronic invoicing requirements. These include:
entities subject to statutory bookkeeping requirements with turnover below NOK 50,000, subject to certain conditions;
certain bankruptcy estates;
financial institutions; and
insurance companies and pension undertakings.
Businesses falling within these provisions do not need to apply to the tax office for an exemption.
In addition to the exemptions mentioned above, the tax office can grant an exemption from the electronic invoice format requirement by way of an individual decision.
The Directorate of Taxes has emphasised, however, that exemptions are to be granted restrictively. The transitional period until 2030 is intended to provide businesses with sufficient time to implement the necessary changes, and further extensions should therefore only be expected in special circumstances.
The Directorate has specifically identified the following circumstances as potential grounds for a temporary exemption:
Winding up the business: The business can document that it will cease operations no later than 30 June 2027. For limited liability companies, this may be documented by way of a resolution by the general meeting to dissolve the company.
Replacement of ERP systems: The business entered into a contract in 2026 for the acquisition of a new, customised ERP system, and the system, including the necessary EHF functionality, will be completed during 2027.
International group structures: The business is a branch or subsidiary of a foreign entity and uses the group’s common invoicing solution. It must be documented that the group is in the process of implementing the necessary EHF/Peppol adaptations and that the solution will be completed during 2027.
To obtain an exemption, the business must submit an application to the tax authorities which will assess each application individually. However, the Directorate of Taxes has clarified that businesses currently using PDF invoices should, as notmally, not expect to be granted an exemption.
Although the legislative amendments are rooted in the bookkeeping rules, they will also have implications for businesses’ handling of VAT.
The approved e-invoicing formats are based on the European standard EN 16931 and contain structured information concerning, among other matters, VAT treatment at transaction level. This facilitates greater automation and improved integration between invoicing, bookkeeping, SAF-T reporting and VAT reporting.
The developments share certain features with the EU’s VAT in the Digital Age (ViDA) initiative, in which electronic invoicing and standardised transaction data play a central role. The Norwegian rules do not, however, introduce the EU models for real-time or transaction-based VAT reporting.
Nevertheless, digital bookkeeping and standardised invoicing data may, over time, facilitate further automation of compliance monitoring and reporting processes. The consultation materials also indicate that the infrastructure may enable future digital solutions related to tax and VAT, although such solutions do not form part of the legislative amendments that have currently been adopted.
Prepare your business by:
assessing whether their existing ERP and invoicing systems support EHF/Peppol;
identifying customers and suppliers registered in Peppol;
reviewing master data and invoicing procedures;
assessing the quality of VAT codes and SAF-T configurations;
planning the necessary system adaptations well in advance of 2027; and
where relevant, considering whether to apply for an exemption.
For businesses facing major ERP transformations, international group projects or a planned winding-up of operations, it may be particularly relevant to assess whether the conditions for a temporary exemption are met. Any applications should be prepared and documented well in advance.
E-invoicing from 2027 involves more than simply introducing a new invoice format. The new regulatory framework establishes a standardised digital infrastructure for the exchange of transaction data between businesses and lays the foundation for more automated accounting and VAT processes.
Businesses that begin their preparations at an early stage will be best positioned to address the technical, regulatory and VAT implications of the new requirements.
Advokatfirmaet Aider Legal, can assist businesses with matters relating to bookkeeping requirements, VAT, SAF-T, ERP implementations, exemption applications and compliance with the new requirements for electronic invoicing and digital bookkeeping.