1. Introduction to New Zealand’s New e-Invoicing Requirement for Large Suppliers
On 9 October 2025, the New Zealand Government officially announced changes to the Government Procurement Rules, introducing new requirements for large suppliers to send e-invoices when contracting with Government agencies. While the new rule isn’t a legal mandate, businesses that are unable to send e-invoices may face challenges securing contracts with government bodies.
From 1 January 2027, all government agencies will require large suppliers, defined as those with revenue exceeding NZ$33 million over the previous two years, to issue e-invoices for domestic transactions. This step is part of the government’s effort to promote e-invoicing adoption across the business landscape, driving efficiency and transparency. The large supplier threshold excludes international suppliers and foreign currency transactions.
2. What Defines a “Large Supplier” in the Context of the New Procurement Rules
The definition of a “large supplier” in the new rule is based on total revenue over the previous two accounting periods. Specifically, a supplier is considered large if their total revenue, combined with that of its subsidiaries, exceeds NZ$33 million.
This criterion only applies to domestic trade invoices issued in New Zealand dollars and for transactions within New Zealand. This means international suppliers and suppliers engaged in cross-border invoicing will not fall under the new e-invoicing requirements.
2.1 Who is Exempt
- Suppliers with revenues under NZ$33 million
- International suppliers
- Cross-border transactions conducted in foreign currencies.
3. Timeline and Phased Implementation of the New e-Invoicing Requirement
While the rule requiring large suppliers to send e-invoices officially comes into effect on 1 January 2027, businesses need to begin preparation as soon as possible to align with the expected procurement cycles. The Government will likely use procurement records and financial disclosures to identify which suppliers are affected by the rule. Agencies will then communicate these requirements to suppliers in advance.
It’s important to note that although e-invoicing is not legally required yet, businesses unable to comply by the 2027 deadline may be excluded from future government contracts.
From 1 January 2026, government agencies will also be required to pay 95% of all domestic trade e-invoices within five business days. Non-compliance with e-invoicing may significantly reduce a supplier’s chance of securing government business moving forward.
4. Key Differences in Domestic and International Scope
The new rules are strictly domestic in scope, applying to transactions within New Zealand and in New Zealand dollars. This focus excludes international suppliers and cross-border transactions, which will continue to follow existing invoicing and reporting practices.
In practical terms, this means foreign suppliers will not be obligated to comply with the e-invoicing rule, as the New Zealand government’s focus is on improving internal, domestic procurement processes.
This narrowing of scope clarifies that the rule’s main objective is to automate and streamline the invoicing processes for large local suppliers dealing with government agencies within New Zealand.
5. How Government Agencies Will Implement e-Invoicing Requirements
Government agencies in New Zealand will begin identifying large suppliers in 2026 through a combination of procurement records and supplier financial disclosures. In 2026, procurement documentation (e.g., RFPs/RFTs) will likely ask suppliers to confirm whether they meet the large supplier criteria and are e-invoice ready.
From 1 January 2027, when contracting with a government agency, large suppliers will need to comply by sending e-invoices. The government’s goal is to fully integrate e-invoicing into the procurement process across the public sector, making e-invoicing an essential part of doing business with government agencies.
As government agencies align their internal systems with the new e-invoicing framework, suppliers will be expected to adopt compatible e-invoicing solutions and integrate them into their ERP or invoicing software.
6. What e-Invoice Readiness Means for Suppliers
To meet these new government procurement requirements, suppliers must be able to send Peppol-compliant e-invoices. New Zealand is part of the Peppol network, a global e-invoicing standard that allows for cross-border interoperability.
For suppliers, this means:
- Adopting Peppol e-invoicing technology: Suppliers will need to use Peppol-certified Access Points (or their ERP systems) to issue compliant e-invoices to government agencies.
- Validating e-invoices: Suppliers should ensure their invoices meet the Peppol PINT A-NZ standard, which is New Zealand’s tailored version of the European EN 16931 standard.
- Receiving e-invoices: Suppliers must be ready to receive e-invoices as part of the government’s broader push for full digital integration.
7. e-Invoicing and the Prompt Payment Rule
Alongside the e-invoicing mandate, the New Zealand government has introduced a prompt payment rule:
- From 1 January 2026, government agencies will be required to pay 95% of all domestic trade e-invoices within 5 business days.
- Standard invoices (non e-invoices) must be paid within 10 business days.
This will encourage suppliers to adopt e-invoicing not only for compliance but also to benefit from faster payments.
For suppliers, this shift will require faster invoicing and tracking of payment times. Suppliers will need to implement systems to track payment terms and ensure timely invoicing in order to meet the new payment obligations and avoid delays.
8. Action Steps for Suppliers to Prepare
Suppliers must start planning for e-invoicing readiness ahead of the 1 January 2027 deadline. Here’s what suppliers should focus on:
- Evaluate size status: Confirm if you meet the NZ$33 million threshold and if you will be required to comply with e-invoicing mandates.
- Choose a Peppol-compliant solution: Ensure your invoicing software can send and receive Peppol e-invoices. If your ERP doesn’t support this, explore integration options with Peppol Access Points.
- Ensure data compliance: Ensure all your invoicing templates meet Peppol PINT A-NZ standards and align with the NZ government’s specific requirements for mandatory fields and data formats.
- Test ahead: Participate in testing with government agencies in 2026 to ensure smooth onboarding before the January 2027 deadline.
- Training & documentation: Train internal teams on e-invoicing best practices, update contracts to reflect e-invoice requirements, and document your readiness.
Conclusion: The Path Forward
As New Zealand leads the way in adopting e-invoicing, large suppliers must prepare for the 1 January 2027 requirement to send compliant e-invoices for domestic transactions. Early adoption of Peppol-compliant solutions will ensure suppliers not only meet the deadline but also benefit from improved operational efficiency and faster payments under the Government’s prompt-payment rules.
Sources
- Peppol New Zealand e-Invoicing: Key policies and standards for compliance
- Government Procurement Rules (5th Edition): Overview and implementation details
- Peppol Authority – New Zealand: Integration guidelines for suppliers
