Regulatory updates - Norway

The proposal sets out the following timeline:

• Requirement to send e-invoices: January 1, 2027
• Requirement to use a digital bookkeeping system that, among other things, receives and processes e-invoices automatically: January 1, 2030

In a follow-up letter, dated March 16, 2026, the Ministry of Finance has asked the Directorate of Taxes (Skattedirektoratet) to prepare the necessary regulatory amendments, including more detailed rules on invoice format, electronic bookkeeping systems, and possible exemptions or postponements for small businesses.

The Directorate is also asked to assess whether similar requirements should be extended to other areas, such as consumer invoicing (B2C), e-receipts, and possible regulation of accounting system providers.

Among the proposals previously discussed are making EHF (Elektronisk Handelsformat) the mandatory e-invoicing format and exempting businesses with turnover below 50,000 NOK (approximately 4,500 EUR) that are not required to keep accounts or submit VAT returns.

 The Directorate's broader review is due by December 15, 2026, and relevant stakeholders are to be involved in the process.

On June 20, 2025, the Norwegian Ministry of Finance released a consultation note outlining plans to require digital bookkeeping and business-to-business (B2B) e-invoicing for all entities with accounting obligations in Norway. This includes both domestic and foreign companies subject to Norwegian accounting requirements.

Key proposals

• Mandatory digital bookkeeping;
• Mandatory B2B e-invoicing.

Scope

The requirements are proposed to apply to all entities with accounting obligations in Norway, including foreign companies with such obligations. Foreign businesses not required to keep Norwegian accounts may choose to use e-invoicing voluntarily. The e-invoicing mandate will not apply when Norwegian businesses invoice foreign customers for exports.

E-invoicing standard

The consultation proposes EHF version 3.0 (based on Peppol BIS and compliant with European Norm EN16931) as the mandatory e-invoicing format. All obligated businesses are proposed to be required to register in the national e-invoicing directory, ELMA, to enable invoice exchange.

Implementation timeline

• January 1, 2028: Requirement to send e-invoices for all entities in scope;
• January 1, 2030: Requirement to receive e-invoices and to bookkeep digitally.

Exemptions

• Sole proprietorships without accounting obligations and with annual turnover below NOK 50,000 are exempt from receiving e-invoices, and only need to send e-invoices if their system supports it;
• Bankruptcy estates;
• B2C (business-to-consumer) and cash sales;
• Special provisions are proposed for financial institutions, pension funds, and insurance companies.

Public consultation

The Ministry of Finance invites stakeholders to provide feedback on the proposal on the government's dedicated website no later than October 31, 2025. Feedback from listed consultation bodies is particularly encouraged to help inform further implementation.

Next steps

The Ministry emphasizes that the proposed phased approach is necessary for businesses to adapt. Non-compliance may be subject to sanctions, with further details to be set in subsequent regulations.

The proposal aims to increase efficiency, improve compliance, and align with the EU's ViDA initiative for digital reporting.

The investigation will take a broad approach, examining requirements for digital bookkeeping, electronic accounting systems and mandatory e-invoicing between private entities.

One potential solution is setting requirements for electronic accounting systems to ensure they support e-invoicing. In this case, the system suppliers will then be responsible for the mandatory functionality in the system. The Danish bookkeeping obligation is explicitly referenced as a possible scenario.

The government aims to finalize the investigation of these requirements by mid-June 2025. However, no further timelines have been communicated regarding the potential e-invoicing model or system coming into effect. Stay tuned for further updates!