The future of e-Invoicing and e-Reporting in Norway

General Background

The beautiful country of Norway, situated on the Scandinavian Peninsula, has been aiming to further foster the digitalization of invoicing and reporting. Their goal being - to digitize the entire ‘order to pay process’. The current mandate imposed, only finds application to central, regional and local public contracting authorities.

 The responsible parties for the gradual implementation and development of electronic invoicing and reporting, consists of the Ministry of Digitalization and Public Governance, the Ministry of Finance and The Norwegian Agency for Public and Financial Management (DFØ). The key role player, being the DFØ, authorizes Norwegian-registered Access Points (AP) and operates the ELMA registry, which is a Peppol Service Metadata Publisher. The object of this eInvoicing and eReporting system is targeted at reducing costs and facilitating tax compliance, streamlining the control processes and simplifying audit procedures.

 What is the current mandate applicable?

 As of 2 April 2019, it has been mandated for all contracting authorities, central and non-central public authorities, to be able to receive and process eInvoices. This led to the mandate expanding to include public entities’ suppliers, who are required to send eInvoices. In terms of the Public Procurement Act, transactions with public authorities valued at over 100,000 NOK (excl. VAT) will fall under the mandate to issue eInvoices. This means that the current mandate in Norway is in respect of Business-to-Government (B2G) transactions.

 The Norwegian government aims to further develop and expand the implementation of eInvoicing and eReporting having regards to Business-to-Business (B2B) transactions and Business-to-Consumer (B2C) transactions, however there are no current plans to introduce mandatory eInvoicing for B2B and B2C transactions.

Since January 2022, Norway has required VAT-returns based on standard SAF-T codes and for companies to create electronic SAF-T files with the purpose of having same submitting their accounting information. SAF-T enables electronic reporting by allowing businesses to export data from their accounting records in XML-format. The platform utilized for digital reporting is the ‘Altinn’-portal, with most enterprises submitting VAT-returns on a bi-monthly basis. The annual tax return for companies, has since 2024, been required electronically via an accounting or annual accounts system.

Despite the gradual implementation of the digitalization of tax collections and returns, it is wise to stay abreast of all possible avenues and the potential of quick changes and legislative amendments.

The Standards and Authorities Applicable

 Norway elected to implement, as the basis for their eInvoicing and eReporting systems, the European standard. Therefore, eInvoices must comply with the definitions and guidelines as stipulated within Directive 2014/55/EU. Directive 2014/55/EU has been encompassed in Norwegian legislation, such as “Regulation on Electronic Invoicing in Public Procurement (FOR-2019-04-01-444), which prescribed the initial roll-out of the eInvoicing mandate in Norway.

The format of the eInvoice has been adapted to conform to the European standard, with the legacy format of EHF (Elektronisk Handelsformat). The eProcurement structure, having been built around the Peppol Business Interoperability Specifications (BIS) and Peppol eDelivery Network, predisposes the system to the Peppol BIS 3.0 format. The Norwegian government thus, recognizes both the EHF format and the Peppol BIS 3.0 format.

The obligation on public entity suppliers, however, only mandates the use of the EHF format as the norm, in order to send eInvoices to public administrations. EHF is hence used exclusively between Norwegian organizations.

Norway is dependent on the Peppol BIS 3.0 and Peppol eDelivery Network with particular reference to cross-border transactions. The Peppol platform allows for the inhibited quick exchange of eInvoice data between suppliers (issuers) and buyers (recipients), foreign and domestic. Nonetheless, non-domestic eInvoices are received through the Peppol platform, easing the administrative burden of the Norwegian government.

 Economic operators and contracting authorities will have to rely on Peppol Access Point (AP) service providers to achieve compliance with national regulations, prior to eInvoice exchange.

 What is the future of eInvoicing and eReporting in Norway?

 As briefly discussed above, no clarification has been made in respect of any timeline of the implementation of eInvoicing over multiple transaction types (i.e. B2B and B2C). Nevertheless, it is clear by the outlined goal of the Norwegian government that eInvoicing and eReporting is yet to come to complete fruition.

P.S.

In 2024, the Norwegian tax authority participate in a pilot, run by the Nordic Smart Government & Business, to report VAT based on invoices between Nordic countries, harmonizing with the EU’s ViDA prerogative.

 Norway is well on its way to develop a comprehensive and accessible eInvoicing and eReporting system.