Norway to Mandate SAF-T Reporting from 2020

Denise Hatem
December 12, 2019

Mandatory SAF-T (Standard Audit File-Tax) reporting will be introduced in Norway from 1 January 2020. Use of SAF-T, a standardized XML format containing exported accounting information, remains voluntary until that date.

SAF-T is designed to reduce compliance and administrative costs for businesses and revenue bodies and enhance audit outcomes.  Its standardized, easily readable layout and format is intended to facilitate both the submission of accounting records to authorities and the performance of internal and external computer-assisted audits. However, SAF-T compliance has proved to be complex, and businesses will need the right tools to navigate this evolving regulatory landscape.  

Background on Norwegian SAF-T

The Norwegian SAF-T is the result of collaboration between the Norwegian Tax Administration, business and accounting communities, software developers, and other stakeholders. It is based on OECD recommendations as to the design, application and its implementation.

  • 2014: Implementation of SAF-T in Norway was recommended by a project group, which included representatives from the tax authority, the Norwegian Institute of Public Accountants, Accounting Norway, and the Confederation of Norwegian Enterprise.
  • 2015: A working group created and tested a first version of the SAF-T Financial.
  • 2016: The first version of the SAF-T Financial was published on the tax authority website.
  • 2017: The administrative body on Norwegian SAF-T standards met with the goal of managing standards to suit both the public and private sectors. Any future SAF-T changes will be done by recommendation of the administrative body.

SAF-T obligations in Norway

Norway’s SAF-T requirements will apply to any enterprise with bookkeeping obligations who use an electronic accounting system, including registered foreign entities. Businesses with less than NOK 5 million in turnover (who are not subject to mandatory electronic bookkeeping) are exempt unless they have electronically available bookkeeping information. The SAF-T requirements don’t apply to enterprises who have fewer than 600 vouchers annually and hold their accounts in a spreadsheet or text editor program, as such programs are considered to be manual solutions.

The Norwegian SAF-T must be submitted upon request in connection with an audit. It’s not a periodic requirement. The first version includes general ledger, subsidiary ledger, and required fixed data.  The SAF-T won’t replace the VAT return in Norway at this time.

“Mandatory” and “optional” elements

The Norwegian SAF-T schema contains “mandatory” and “optional” elements. The Norwegian tax authority has emphasized that “optional” data elements shouldn’t be omitted unless the data isn’t available in the system. Fields should not be empty, even if there is no data to populate an “optional” element. OECD guidance indicates that meaningful placeholder information must be supplied where information to populate an element isn’t available. Numeric and date fields will fail validation if they are sent as empty elements. The file will not validate without “mandatory” elements, and most “mandatory” elements involve information that is required to be kept by regulation.

As OECD guidance explains, revenue bodies would normally expect all elements to be included because the SAF-T specification includes only information likely to be found in most accounting software packages.  

Submission of Norwegian SAF-T files

SAF-T files will be submitted primarily by upload via the Altinn internet portal. The size limitation in Altinn is 200MB per attached file and 2GB of source XML data. If use of Altinn is not possible, taxpayers must contact the relevant case handler in the tax authority. The tax authority strongly advises use of the following naming convention: <SAF-T export type>_<organization number of the vendor who the data represents>_<date and time (yyyymmddhh24hmise)>_<file number of total files>.xml. Testing of submissions is available and recommended by the tax authority.

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Denise Hatem

Denise Hatem is a Regulatory Counsel at Sovos specializing in international taxation, with a focus on value added tax systems in the European Union. Denise received her B.A. from the University of Connecticut and her J.D. from Notre Dame Law School. She is an active member of the Massachusetts Bar.
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