As expected, the approved invoice formats for invoicing between Norwegian entities subject to bookkeeping obligations will mirror the current formats for invoicing to government entities (B2G).
Four standards are approved from 1 January 2027: EHF Invoicing, Peppol BIS Billing, EHF Self-Billing and Peppol BIS Self-Billing. All formats must be version 3.0 or later. PDF, paper and other non-machine-readable formats are not approved formats for electronic invoicing.
A transitional arrangement is also introduced, allowing other structured electronic invoice formats to be used until 31 December 2029, provided an agreement is entered into with the invoice recipient. In its explanatory notes, the Norwegian Tax Administration specifies that examples of such formats include EDIFACT and E2B.
In practice, the phased introduction means that Norwegian entities subject to bookkeeping obligations must send e-invoices to customers who are already able to receive them during the period 2027 to 2029. Customers who are not yet registered do not trigger the obligation to send e-invoices for the time being. In such cases, an ordinary PDF invoice will be sufficient. From 2030, e-invoices will be the new standard, as all entities within the scope must be able to both send and receive e-invoices.
A clarification is also introduced stating that from 1 January 2028, sales documentation must always be sent to buyers subject to bookkeeping obligations, and the buyer’s organisation number must always be stated on the invoice. This represents a tightening of the current rules. Under the current Norwegian Bookkeeping Regulations Section 5-1-2, first paragraph, it is sufficient to state the buyer’s name and either address or organisation number — meaning that the organisation number is currently an alternative to the address, not a mandatory requirement. From 2028, the organisation number will be required for all invoices to buyers subject to bookkeeping obligations. All such entities should therefore already now verify that their sales documentation includes the buyer’s organisation number, to ensure a smooth transition.
Electronic accessibility: Previously, businesses with turnover below NOK 5 million were exempt from the requirement to keep recorded information electronically accessible. This exemption is being removed from 2027. Upon winding down of a business, the information must be kept accessible for at least six months after the date of winding down.
Storage of e-invoices: From 2027, e-invoices must be stored in their original format. This means that the structured data file cannot be replaced with a printout or PDF during the retention period.
Updated statutory references: The rules on buyer and seller identification now refer to the new Entity Register Act of 2025. These changes are of a technical nature only.
The amending regulations mean that all technical requirements and details are finalised before the legislative changes come into force on 1 January 2027. All legal entities subject to bookkeeping obligations should therefore make the following assessments:
PwC assists businesses with questions related to invoicing, bookkeeping and tax reporting. Wondering whether your system is ready for the 2027 requirements? Contact one of our experts for a non-binding consultation.