Every bookkeeping-liable business must be able to send e-invoices from 2027

From 1 January 2027 every Norwegian business subject to bookkeeping duties (bokføringspliktig) must issue sales documentation to other bookkeeping-liable businesses in electronic invoice formatLovdata. Stortinget vedtok endringene i bokføringsloven i juni, and the resulting amendment act (LOV-2026-06-19-39) brings the e-invoicing provisions into force on 1 January 2027Lovdata, with the duty to keep books in an electronic accounting system following on 1 January 2030Lovdata. An electronic invoice is a sales document that can be issued, sent and received in a structured electronic format suitable for automated processing in the accounting system — a PDF attached to an email does not satisfy the requirement.

The send duty covers recipients registered in ELMA, the electronic recipient register.Revisorforeningen That sounds like a limitation that buys time until the 2030 receive duty, but it does not. The state and the municipalities have required e-invoices for years and sit in ELMA, as do most large companies and a large share of small and medium-sized businesses. In practice nearly every bookkeeping-liable business has at least one customer it must send e-invoices to from 1 January 2027.Revisorforeningen The register decides which invoices must go as e-invoices and which may still go as PDF — not whether a business needs the capability at all. Sales to consumers and cash sales fall outside the duty.Revisorforeningen

Two things remain undecided. The regulations setting the format and the exemptions have not been adoptedRevisorforeningen: Skattedirektoratet has reviewed the hearing responses and the regulations now sit with Finansdepartementet for endorsement, with no adoption date announced. The hearing draft proposed EHF as the format, with exemptions including sole proprietorships (enkeltpersonforetak) with turnover below NOK 50,000 and no accounting or VAT duties, bankruptcy estates without business activity, and certain document types in financial and insurance undertakings; invoicing to and from foreign parties not bookkeeping-liable in Norway was also kept outside. The details may still be adjusted — not least because the hearing draft assumed the send duty would start in 2028.

The formal duty to keep books in an electronic accounting system only starts in 2030, but anyone sending e-invoices from 2027 needs a system that can produce them — for most businesses 2027 is the real deadline. In many standard accounting systems this is a setting; businesses with proprietary systems, or whose systems are controlled from abroad, face a project that must start now. The Act allows exemptions by regulation or individual decision, but with the regulation not adopted and no dispensation practice in place, no business should plan on a postponement.

For auditors, missing e-invoicing is a breach of the bookkeeping rules from 1 January 2027Revisorforeningen, to be assessed as part of the audit under revisorloven § 9-4 and raised in writing with the board under § 9-5 where material. The first financial year fully covered is 2027Revisorforeningen, so autumn 2026 and the planning of the 2027 audit — not the final audit in spring 2028 — is the time to act. Three questions to put to clients now: can their system send e-invoices in EHF format today, and is the function in use; who owns the invoicing system and do they know the deadline — if the decision sits with a foreign head office or a system vendor, the matter must be escalated there now; and how many systems issue invoices — groups, trade systems and proprietary solutions must each be handled separately.

Legal basis: bokføringsloven §§ 3, 7 fourth paragraph and 10 second paragraph under LOV-2026-06-19-39Lovdata.