Country deep dive
Norway's mandate is now genuinely enacted law, not a proposal — and it's deliberately asymmetric: issuing arrives three years before receiving does.
Public sector entities and their suppliers must use EHF/Peppol BIS Billing 3.0 over the Peppol network — the infrastructure the 2027 B2B mandate builds directly on top of.
The Ministry of Finance publishes an initial consultation examining mandatory digital accounting and invoicing between businesses, based on a report from the Directorate of Taxes.
A follow-up letter asks the Directorate of Taxes to prepare detailed regulatory amendments covering invoice format, electronic bookkeeping systems, and possible small-business exemptions.
Parliament approves the Act on Amendments to the Bookkeeping Act and Certain Other Laws in the Financial Market Area, confirming the transition from proposal (Prop. 44 L) to binding statutory regime.
Final rules on invoice format specifics, digital bookkeeping system criteria, and any exemptions or postponements for small businesses are due by this date.
All businesses subject to Norwegian bookkeeping obligations must issue structured EHF invoices to any recipient already registered in ELMA. PDF invoices to ELMA-registered counterparties are no longer valid from this date.
The reciprocal obligation lands: businesses must use an electronic accounting system capable of automatically receiving and processing e-invoices, completing the two-phase reform.
EHF is Norway's own name for what is, underneath, a Peppol BIS Billing 3.0 document — there's no separate national schema to learn.
EHF is typically used for domestic transactions while Peppol BIS handles both domestic and cross-border — for compliance purposes, both satisfy the legal requirement equally.
Routing identity ties directly to the organisation number — get this field wrong and delivery simply fails, regardless of how correct the rest of the invoice is.
If a foreign entity holds Norwegian bookkeeping obligations, there's no lighter-touch version of the mandate — the exact same EHF rules apply when invoicing domestic business partners.
A future B2C e-receipts framework is being separately assessed by Skattedirektoratet — worth watching, but not part of the current B2B reform.
Norway's mandate is deliberately asymmetric for three years — a design choice, not an oversight, aimed at giving buyers time to catch up.
There's no requirement for point-to-point connections between trading partners — this is the same architecture powering Belgium's and the UK's B2B mandates.
Senders must automatically query ELMA to verify a buyer's e-delivery address and capability before transmitting — this lookup is what determines whether the 2027 issuing obligation even applies to a given recipient.
This creates a genuine three-year gap where the sending obligation runs ahead of any universal receiving requirement — deliberately designed to give SMEs a longer runway to adapt.
If you already self-bill, don't assume that arrangement is grandfathered out of the structured-format requirement once 2027 arrives.
Norway's existing voluntary adoption is already high (84–89%), so for many businesses this is a matter of formalising practice already in place.
Confirm your organisation is listed and discoverable in the national receiver register, now integrated into the Peppol directory — this is a prerequisite for both sending and receiving.
Choose a provider well before Q3 2026 to allow time for integration and testing ahead of the January 2027 deadline.
Validate that outgoing invoices are correctly structured Peppol BIS Billing 3.0 XML — this is the same underlying format regardless of whether you call it "EHF" or "Peppol BIS" internally.
Query ELMA automatically before transmission to check whether a given recipient is registered and what capability they've declared — this determines whether the structured-format obligation applies to that specific invoice.
If you have a local presence that triggers Norwegian bookkeeping rules, plan for identical EHF compliance — there's no separate lighter regime for non-Norwegian companies.
Even though reception isn't mandatory until 2030, the three-year runway is there to be used — don't leave the automatic-receiving-and-processing requirement until the last minute.
Skatteetaten and Digdir offer guidance, SAF-T documentation, and Peppol information, including free webinars — genuinely worth using given the technical detail still being finalised through late 2026.
No clearance model or real-time reporting exists yet — but the infrastructure being built quietly creates the preconditions for one.