Norway’s Tax Administration (Skattedirektoratet) has published a formal consultation document (høringsnotat) containing a proposal to introduce mandatory digital bookkeeping and mandatory B2B e-invoicing for businesses subject to bookkeeping obligations. These changes are proposed as amendments to the Bookkeeping Act and Bookkeeping Regulations.
The proposal outlines a phased implementation, with the requirement to send electronic invoices taking effect from 1 January 2028, followed by mandatory electronic invoice reception and digital bookkeeping from 1 January 2030.
While the proposal does not include transaction-based reporting to tax authorities, the document notes that mandatory e-invoicing could eventually enable real-time tax and VAT reporting capabilities. However, the exploration of these possibilities is excluded from the current proposal’s scope.
Scope of Application
The proposed changes apply to all businesses with bookkeeping obligations in Norway. Certain exemptions are foreseen, including sole proprietorships with annual turnover below NOK 50,000 (approx. EUR 4,300), provided they are not subject to accounting or VAT registration requirements, as well as certain bankruptcy estates and other specific cases.
The proposed e-invoicing requirements apply to B2B transactions, while excluding sales to consumers (B2C) and cash sales. B2G e-invoicing is already mandatory in Norway under existing legislation.
E-invoicing Standard in the Proposed Regulation
The proposal specifies that EHF, the Elektronisk Handelsformat version 3.0 or newer would become the required standard for electronic invoicing. This format is already widely adopted in Norway and is harmonized with European standards.
Proposed Definition of Electronic Invoice
The draft amendments to the Bookkeeping Act include a formal definition of an electronic invoice as a sales document that can be issued, sent, and received in a structured electronic format suitable for automated processing in accounting systems. PDF invoices would no longer qualify as electronic invoices.
Electronic Bookkeeping Requirements
The proposal requires businesses to use electronic accounting systems for their bookkeeping processes, eliminating the use of manual bookkeeping using paper-based systems or tools like spreadsheets. Digital bookkeeping is defined as the use of software or digital service that enables both the production of mandatory accounting reporting and specifications, and the automated processing of electronic invoices, forming a comprehensive electronic accounting system. These systems must maintain bookkeeping information in electronic form for 3.5 years after the end of the financial year and be able to reproduce this information in standardized formats.
What’s Next
The public consultation on this proposal is open until 31 October 2025. After this date, the authorities will review the feedback received before finalizing their recommendations on the implementation of mandatory digital bookkeeping and e-invoicing.
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