Ready, Set, E-invoice: new rules arrive in 2027 for B2G

By Jeanne Du Buisson & Haidee Watkin

A new chapter in the New Zealand Government’s e-invoicing mandate will begin on 1 January 2027. Large suppliers will soon be required to send e-invoices when dealing with government agencies that issue or receive more than 2,000 domestic trade invoices each year. For large suppliers looking to secure government contracts, it is time to ensure that you are ready to comply with the new e-invoicing requirements before the start of 2027.

First things first: are you a large supplier?

A New Zealand entity is considered a large supplier if it meets either one of the two tests:

• Asset test: The total assets of the entity and its subsidiaries exceed $66 million as at the balance date of each of the two preceding accounting periods; or
• Revenue test: The total revenue of the entity and its subsidiaries exceed $33 million in each of the two preceding accounting periods.

What will need to be e-invoiced?

The mandate applies to domestic trade invoices. Broadly, these are invoices for goods or services supplied in New Zealand by an entity carrying on business in New Zealand, where the payment is in New Zealand dollars.

Not every invoice will be caught. Certain cross-border transactions, transactions denominated in foreign currencies and invoices issued by suppliers that do not meet the large supplier threshold will fall outside the scope of the mandate.

The mandate only applies to invoices that a government agency would ordinarily issue or receive as part of its day-to-day business. It is not intended to capture unusually large or complex transactions (such as those connected with major infrastructure projects), where further checks and approvals would generally be required before payment is made.

How will e-invoices be exchanged?

The New Zealand Government has adopted the PEPPOL framework for e-invoicing. PEPPOL provides a secure network through which suppliers and government agencies can exchange e-invoices directly between their accounting systems.

An e-invoice is more than an invoice sent by email. Instead of attaching a PDF, the invoice information is sent electronically from one accounting system to another. This can reduce manual handling and make invoices quicker and easier to process.

Earlier e-invoicing requirements focused on ensuring that government agencies could receive and send e-invoices. Bringing large suppliers into the mandate is the next step and encouraging the uptake of e-invoicing across the wider New Zealand business community.

Which payments fall outside the mandate?

Some transactions will not require an e-invoice, including:

• Employee expense reimbursements
• Rent and lease payments
• Credit card statements
• Finance payments
• Insurance premiums
• Regular payments under an ongoing contract where an invoice is not required.

What should large suppliers do now?

Although the new requirements will not take effect until 1 January 2027, large suppliers that prepare early will be better placed to implement e-invoicing in their dealings with government agencies. As a first step, businesses should confirm whether they meet the large supplier test, review their current invoicing processes and consider what changes may be needed to implement PEPPOL e-invoicing.

If you would like to discuss e-invoicing or how Deloitte can support your invoicing transformation journey, please contact your usual Deloitte adviser.