Norway: The B2B E-Invoicing Mandate Starts on 1 January 2027 - Fixing the Invoice Format Has Still Not Been Consulted On

KGT Country Update | 15 September 2026 | VAT, e-invoicing and SAF-T monitor

Norway enacted its business-to-business electronic invoicing obligation on 19 June 2026 through Act 2026-06-19-39, amending the Bookkeeping Act. The issuing obligation commences on 1 January 2027 and the digital bookkeeping obligation on 1 January 2030.

The Act does not name an invoice format; it leaves that to a regulation, and it has delegated the power to make it to the Norwegian Tax Directorate. As at 15 September 2026, a review of the Tax Administration's own consultation register shows no consultation on that regulation. The mandate is therefore under four months away, and the legally binding format has not been put out for comment.

Background

Norway has operated a public sector electronic invoicing regime for years, built on the national EHF specifications and the ELMA address register, and has required SAF-T Financial reporting on demand since 2020. It has not had a general obligation for businesses to invoice each other electronically.

That changed in 2026. The Ministry of Finance presented Proposition 44 L (2025 - 2026) on 20 March 2026, proposing a mandatory business-to-business electronic invoicing obligation together with a later digital bookkeeping obligation.

The Storting adopted the Act on 8 June 2026 as Legislative Decision 52 (2025 - 2026), following recommendation 262 L (2025 - 2026). The Act was sanctioned on 19 June 2026 as Act 2026-06-19-39, and the King in Council fixed its commencement that day.

The original plan had been to commence the invoicing obligation in 2028. The Government brought it forward by a year to accelerate business digitalization. That acceleration is the reason the current gap matters: the timetable was compressed, but the implementing regulation has not kept pace.

The Legislative Change

Act 2026-06-19-39 amends the Bookkeeping Act. Most of the Act entered into force on 1 July 2026. The Bookkeeping Act amendments are the exception and commence in two stages: 1 January 2027 and 1 January 2030.

From 1 January 2027, entities subject to Norwegian bookkeeping obligations must issue structured electronic invoices for covered transactions. From 1 January 2030, businesses must use digital bookkeeping systems that can automatically receive and process electronic invoices. The Ministry of Finance has stated that it will issue transitional rules so that the obligation to receive electronic invoices must be met by 1 January 2030.

Two points in the Act are frequently misreported and should be stated precisely. First, this is enacted law, not a proposal. Coverage describing Norway as "advancing towards" or "proposing" a mandate is out of date by several months. Second, the Act does not specify the invoice format.

It provides that the format is to be set by regulation, and that exemptions may be granted by regulation or by individual decision. The regulation-making power and the individual decision power have both been delegated to the Norwegian Tax Directorate.

The Gap: No Consultation on the Format Regulation

The Norwegian Tax Administration publishes its consultations in a single register. A review of that register on 15 September 2026, covering 114 entries sorted by publication date, shows the most recent consultation as one of 3 July 2026 concerning a regulation under the new Act on excise duties. The register contains no consultation on electronic invoicing, EHF, or the invoice-format provisions of the Bookkeeping Regulation.

The only Bookkeeping Regulation consultation in the register is dated 12 November 2024 and is unrelated: it concerns the correction of outdated cross-references to the former Auditors Act in section 8-1-5, which governs the retention of timesheets in the construction industry, together with terminology alignment in sections 5-2-2, 5-2-4 and 8-1-2a following the introduction of the Tax Administration Act. Its comment deadline was 12 February 2025, and its reference is 2024/2864. It has nothing to do with electronic invoicing and should not be mistaken for the implementing regulation.

This is a negative finding, based on the Tax Administration's own published register rather than inference. A regulation can be made without prior consultation, but that would be unusual for an instrument of this significance and would further compress vendor lead times.

What This Means for the Format

EHF, the Norwegian electronic invoice format based on Peppol BIS Billing 3.0, is the obvious candidate and is named in Proposition 44 L. But it is named there as a proposal. Until the regulation is made, no source states that EHF is the legally mandated format, and businesses should be careful with vendor material that presents it as settled.

In practice the risk of building to EHF and Peppol BIS Billing 3.0 is low, because that is the established Norwegian infrastructure and the direction of travel is clear. The genuine risks lie elsewhere: in the version of the specification that will be mandated, in whether the ELMA registration model is carried across from the public sector regime unchanged, in the treatment of foreign entities registered for Norwegian VAT, and in the exemption thresholds. Proposition 44 L discussed a possible exemption for sole proprietorships below a low turnover threshold, but an exemption discussed in a proposition is not an exemption in force.

Scope

• Entities subject to Norwegian bookkeeping obligations. On the face of the Act this includes foreign entities registered for Norwegian VAT where they invoice Norwegian customers, though the detailed scope depends on the regulation.
• Structured electronic invoices for covered business-to-business transactions from 1 January 2027. Paper invoices and emailed PDF documents will not satisfy the obligation for covered transactions.
• Digital bookkeeping systems capable of automatically receiving and processing electronic invoices from 1 January 2030.
• The model is decentralised. There is no central clearance platform and no obligation to transmit invoices to the tax authority in real time. This distinguishes Norway sharply from Poland, Romania or Serbia.

Timeline

• 20 March 2026 Proposition 44 L (2025–2026) presented by the Ministry of Finance.
• 8 June 2026 Storting adopts the Act; Legislative Decision 52 (2025–2026).
• 19 June 2026 Act 2026-06-19-39 sanctioned; commencement fixed by the King in Council.
• 1 July 2026 most of the Act enters into force.
• 1 January 2027 obligation to issue structured electronic invoices commences.
• 1 January 2030 digital bookkeeping obligation, and the date by which the obligation to receive electronic invoices must be met under the announced transitional rules.
• Outstanding the Tax Directorate regulation fixing the invoice format and exemptions. No consultation published as at 15 September 2026.

Businesses Affected

Any group with a Norwegian bookkeeping-liable entity, and any foreign entity registered for Norwegian VAT that invoices Norwegian customers. Groups already sending EHF invoices to Norwegian public bodies have most of the capability in place and are chiefly exposed on scope and registration rather than on format. Groups that invoice Norwegian business customers only by PDF have a genuine implementation ahead of them with less than four months of certainty remaining.

Norwegian entities should also note the interaction with SAF-T. SAF-T Financial version 1.40 becomes mandatory from 1 January 2027, the same date as the invoicing obligation. Two obligations landing on the same date is a resourcing problem as much as a technical one, and the two draw on overlapping master data.

Required Actions

• Treat 1 January 2027 as a firm date. It rests on an enacted Act, not on a proposal, and is not contingent on the regulation being made.
• Build to EHF over Peppol BIS Billing 3.0 as the working assumption, but do not hard-code a specification version and do not sign off the design as final until the regulation is published.
• Confirm ELMA registration for every Norwegian-invoicing entity, and confirm which endpoint identifiers are used and who owns them.
• Establish whether any foreign entity in the group holds a Norwegian VAT registration and invoices Norwegian customers, since those entities may be in scope without having a Norwegian establishment.
• Sequence the e-invoicing work with the SAF-T Financial 1.40 change, which shares the 1 January 2027 date, and run them as one Norwegian workstream rather than two.
• Monitor the Tax Administration consultation register directly. Because the regulation has not been consulted on, the lead time between publication and commencement may be very short.
• Raise the lead-time risk with your software vendor now. A vendor cannot certify against a specification that has not been mandated, and the compressed window is a shared exposure.

Practical Implications

The substantive point for planning is that the legal obligation and the technical specification are on different clocks. The obligation is fixed and close. The specification is not yet fixed at all. That combination is uncomfortable but not unusual, and the correct response is to build the capability against the established Norwegian infrastructure while keeping the format layer configurable.

The second implication is about how Norway is being reported. A steady stream of commentary through August and September 2026 described the Norwegian mandate as a proposal or a roadmap. It is neither. Teams relying on that framing may have deferred work that should already be under way, and the deferral is more costly because the commencement was pulled forward a year.

Third, the decentralised design is a genuine advantage that is easy to underestimate. There is no clearance platform to integrate with, no acknowledgement to reconcile and no real-time reporting channel. For a group already operating Peppol elsewhere in Europe, Norway is among the least demanding mandates to satisfy, provided the registration and scope questions are answered correctly.

Expected Next Steps

The Tax Directorate regulation is the instrument to watch. It will set the mandated format and version, the exemptions and any thresholds, and determine how much of the existing public sector infrastructure carries across. Given that the mandate commences on 1 January 2027, publication should be expected in the autumn of 2026. KGT will report the consultation and the final regulation when they appear.

How Can KGT Support You?

KGT delivers SAP-integrated electronic invoicing and statutory reporting. For Norway, we implement EHF over Peppol from SAP billing data, manage ELMA registration and endpoint identifiers, and deliver SAF-T Financial extraction from the same master data, so that the 1 January 2027 invoicing obligation and the SAF-T Financial 1.40 change are handled as a single scope rather than as competing projects.

Because the format regulation is outstanding, we design the Norwegian solution with the specification version as a configurable parameter rather than as a hard-coded assumption, which is what allows a late-published regulation to be absorbed without redesign. For clients on SAP Document and Reporting Compliance, we support scoping, country activation, and testing, and we advise on where an add-on fits better than a DRC country version.

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