Norway: Final E-Invoicing Regulation Adopted on 29 September 2026 Approves EHF and Peppol BIS 3.0, While the Obligation to Receive Is Deferred to 1 January 2030

KGT Country Update | 2 October 2026 | VAT, e-invoicing and SAF-T monitor

On 30 September 2026 the Norwegian Tax Administration published the Tax Directorate’s regulation amending the Bookkeeping Regulation, adopted on 29 September 2026, which fixes the approved e-invoice formats for the obligation to issue electronic invoices from 1 January 2027.

Five days earlier, on 25 September 2026, the Ministry of Finance adopted a transitional regulation under which the obligation to receive e-invoices need only be met by 1 January 2030, and formally delegated rule-making and exemption powers to the Tax Directorate.

This update supersedes parts of our Norway note of 15 September 2026. That note reported that no consultation on the format regulation had been published and that the format was not yet fixed. The final regulation now states that it follows up the proposals consulted on from 1 July 2025 under the title “Pliktig digital bokføring og e-fakturering”, and it names the formats.

The position on the format is therefore settled, and the earlier statement that no consultation had been found should be disregarded.

Background

Norway enacted its business-to-business e-invoicing obligation through Act 19 June 2026 no. 39, which amends the Bookkeeping Act. The Ministry of Finance announced on 19 June 2026 that the Bookkeeping Act changes on mandatory e-invoicing and digital bookkeeping enter into force on 1 January 2027 and 1 January 2030, and that the invoice format rules would be set by regulation, with a transitional rule on receiving.

The three instruments published between 25 and 30 September 2026 are the implementing layer that the Act left open: the transitional rule, the delegation decision, and the amended Bookkeeping Regulation.

The Legislative Change

Transitional regulation (Ministry of Finance, 25 September 2026). The “Forskrift om overgangsregel til lov 19. juni 2026 nr. 39” provides that the requirement that documentation for purchased goods and services from other accounting-liable entities be received in electronic invoice format must be fulfilled by 1 January 2030.

It entered into force immediately and rests on Part VII, section 2 of the Act. The Ministry states that this is in line with its assessment in Prop. 44 L (2025–2026).

Delegation (Ministry of Finance, 25 September 2026). The Ministry delegated to the Tax Directorate the authority to make regulations and individual decisions under sections 7 and 10 of the Bookkeeping Act, including exceptions from the new requirements. The Ministry notes that this is in line with earlier delegation decisions from 2024.

The Tax Directorate will in turn delegate the power to take individual decisions to the tax office, so applications for exemption are to be sent to the tax office.

Amended Bookkeeping Regulation (Tax Directorate, adopted 29 September 2026, published 30 September 2026). According to the Tax Administration’s publication, the regulation implements the 1 July 2025 consultation proposals with some adjustments and with a transitional provision added. Its main content, as presented by the Tax Administration, is set out under Scope and Timeline below.

This is a binding, adopted regulation, not a proposal.

Scope

• Issuing from 1 January 2027. Accounting-liable entities must issue electronic invoices when selling goods and services to other accounting-liable entities (Bookkeeping Act section 10(2)).

• Approved formats. Section 5-2-9 of the Bookkeeping Regulation names “EHF Fakturering, Peppol BIS Billing, EHF Selvfakturering og Peppol BIS Self-Billing”, all in version 3.0 or newer. Both invoices and self-billing invoices are therefore covered.

• Transitional formats until 1 January 2030. Until that date other electronic invoice formats may be used if they meet the statutory definition, that is, a structured electronic format suitable for automated processing in the accounting system. The Tax Administration gives EDIFACT and “E2B” as examples and states that a PDF invoice does not have these properties. For a buyer able to receive electronic formats, a PDF therefore does not discharge the obligation.

• Receiving from 1 January 2030 under the Ministry’s transitional regulation, and digital bookkeeping in an electronic accounting system from the same date, subject to exemptions by regulation or decision.

• Exemptions. The regulation provides exemptions for bankruptcy estates (section 1-1), financial enterprises (section 8-13-2) and insurance and pension undertakings (section 8-14-2). Section 1-2 provides an exemption for accounting-liable persons whose turnover does not exceed NOK 50,000 in a calendar year, on conditions set out in that section; the Tax Administration presents it in connection with the digital bookkeeping requirement.

• Other changes. The exemption from the electronic accessibility requirement that applied to businesses below NOK 5 million revenue is repealed from 1 January 2027 (section 7-7(3)). From 1 January 2028 the buyer’s organization number must be stated in the sales document (section 5-1-2), and parties may no longer agree that all or part of the sales document is not to be transmitted (section 5-2-1).

Timeline

• 25 September 2026 — Ministry of Finance adopts the transitional regulation and the delegation decision; both effective immediately.

• 29 September 2026 — Tax Directorate adopts the amending regulation; published on 30 September 2026.

• 1 January 2027 — obligation to issue electronic invoices in the approved formats; low-revenue exemption from electronic accessibility repealed.

• 1 January 2028 — buyer organization number on sales documents; mandatory transmission of the sales document.

• 1 January 2030 — obligation to receive electronic invoices; digital bookkeeping requirement; end of the transitional period for other structured formats.

Businesses Affected

Every Norwegian accounting-liable entity that sells to another accounting-liable entity is affected on the issuing side from 1 January 2027. Because the Act applies to entities subject to Norwegian bookkeeping obligations, groups should confirm whether any foreign entity with a Norwegian bookkeeping obligation or VAT registration invoices Norwegian business customers; the regulation text should be checked on that point.

Groups that already send EHF to Norwegian public bodies have the format capability in place. Groups that invoice Norwegian business customers by PDF have roughly three months to move to EHF or Peppol BIS Billing 3.0, or to another structured format that qualifies under the transitional provision.

Required Actions

• Treat 1 January 2027 as fixed and plan to issue in EHF Fakturering or Peppol BIS Billing, version 3.0 or newer. Use the transitional allowance for other structured formats only where a documented business reason exists and the format is demonstrably suitable for automated processing by the buyer.

• Do not rely on PDF for any customer able to receive a structured invoice.

• Include self-billing flows. EHF Selvfakturering and Peppol BIS Self-Billing are named separately.

• Plan the 1 January 2028 changes now: capture the buyer organization number in master data and remove any contractual arrangements under which sales documents are not sent.

• Align the workstream with SAF-T Financial version 1.40, which is mandatory from the same 1 January 2027 date, because both draw on the same master data.

• Re-check any project plan or vendor commitment that assumed the format was unconfirmed, and re-check the regulation text on Lovdata for the exemption wording.

Practical Implications

The principal change from the position in mid-September is certainty. The format layer is now fixed to named Peppol-based specifications, and the receiving side is deferred by three years, which separates the sending project from the larger accounting-system project. The 2030 date is a deadline for receiving, not a postponement of issuing: the 2027 issuing obligation is unchanged.

The transitional provision is more permissive than the headline format list suggests, but it is bounded by the suitability-for-automated-processing test and by the date. Businesses that choose EDIFACT or another existing format for 2027 take on a second migration before 2030.

We also note that our 15 September note described the delegation to the Tax Directorate as already in place. The formal delegation decision referred to in this update is dated 25 September 2026, although the Ministry describes it as consistent with 2024 delegations; the practical point is that the regulation-making and exemption powers now sit with the Tax Directorate and tax office.

Expected Next Steps

Watch for the Tax Administration’s guidance for businesses and for any technical guidance on ELMA registration and the Peppol BIS Billing version to be used. Individual exemption applications go to the tax office once it holds the delegated power.

The Tax Administration’s publication points to the regulation text on Lovdata, which should be reviewed as soon as it is available to confirm section references and exemption conditions.

How Can KGT Support You?

KGT delivers SAP-integrated electronic invoicing and statutory reporting. For Norway we generate EHF and Peppol BIS Billing 3.0 invoices, including self-billing, directly from SAP billing and procurement data, manage ELMA and endpoint registration, and deliver SAF-T Financial extraction from the same master data so that the 1 January 2027 invoicing date and the SAF-T 1.40 change are handled as one scope.

For clients on SAP Document and Reporting Compliance we support scoping, country activation and testing, and we advise on whether an SAP-integrated add-on or a DRC country version is the better fit for the 2027 and 2030 milestones.

This country update is provided for general information only and does not constitute tax, legal or professional advice.