20 October 2025

New Zealand Government strengthens business-to-government e-invoicing requirements

  • The New Zealand Government (the Government) on 9 October 2025 introduced a new e-invoicing rule as part of its Government Procurement Rules.
  • From 1 January 2027, Government agencies will require large suppliers, defined as those with total revenue exceeding NZ$33m in the previous two accounting periods, to send e-invoices.
  • Although sending e-invoices is not legally mandated, suppliers unable to do so may find it challenging to secure contracts with Government agencies.
  • Businesses should begin preparations to be e-invoice ready by the deadline, as Government agencies will likely assess supplier readiness in advance.
 

The New Zealand Government (the Government) announced on 9 October 2025 that the fifth edition of the Government Procurement Rules (the Rules) have been finalized and will be live from 1 December 2025. From 1 January 2027, Government agencies, which must follow the Rules, will need to require large suppliers to send e-invoices when contracting with them.

Although the change is not a legal requirement, suppliers who cannot send e-invoices are less likely to secure contracts with Government agencies.

The change is part of the Government's approach of taking the lead in adopting e-invoicing to help encourage businesses to adopt e-invoicing.

Who is affected?

A supplier is defined as a "large supplier" if, in each of the preceding two accounting periods, the total revenue of the entity and its subsidiaries exceeded NZ$33m.

For purposes of the Rules, the focus is on domestic trade invoices, meaning transactions in which goods and services are supplied and invoiced in New Zealand dollars within New Zealand. Therefore, the "large supplier" definition does not apply to international suppliers or invoices.

How Government agencies will apply the requirement

In advance of 1 January 2027, Government agencies are likely to identify large suppliers through agency procurement records (showing the extent of purchases from existing suppliers) and supplier financial disclosures and communicate the requirements.

Businesses can expect requests for proposals with Government agencies to require businesses to identify whether they are large and e-invoice ready.

Implications

Though the Government has communicated that existing Government suppliers who are unable to immediately comply with the deadline may be allowed to use existing invoicing channels for a limited period, large suppliers wishing to continue to contract with Government agencies should start preparing now to be e-invoice ready by 1 January 2027.

Note that, along with the changes described above, Government agencies are required, from 1 January 2026, to pay 95% of all domestic trade e-invoices within five business days (and standard invoices within 10 business days).

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young Limited, New Zealand

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-2116