Government agencies' requirements: large suppliers eInvoicing
From 1 January 2027, government agencies must ensure that large suppliers send eInvoices.
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From 1 January 2027, government agencies that must follow the Government Procurement Rules will need to require their large suppliers to send eInvoices.
The following information provides guidance to government agencies to meet this requirement.
Definition of large business
Large supplier has the same meaning as in section 45(b) of the Financial Reporting Act 2013 and is defined as large if in each of the 2 preceding accounting periods the total revenue of the entity and its subsidiaries (if any) exceeds $33 million.
This is based on the supplier's total revenue, not the amount your agency spends with them.
Government Procurement Rule 44: eInvoicing capability(external link) — NZ Government Procurement
Section 45 of the Financial Reporting Act 2013(external link) — New Zealand Legislation
The large business definition doesn’t apply to international suppliers
For the purposes of the eInvoicing requirements described in NZ Government Procurement Rules, the focus is on domestic trade invoices - meaning those transactions where goods or services are supplied and invoiced in New Zealand dollars within New Zealand.
Application of the requirement
The requirement is expected to be implemented through procurement and contract management processes. In practice, government agencies should consider adding eInvoicing requirements when:
- New contracts are established
- Existing contracts are renewed
- Transitioning to eInvoicing upon mutual agreement between suppliers and agency
- Contracts are retendered
- Significant contract variations occur
eInvoicing requirements will not be retrospectively applied to existing contracts.
This means 1 January 2027 is not a hard deadline requiring every large supplier to be immediately capable of sending Peppol eInvoices. Rather, agencies are expected to work towards incorporating the requirement through their procurement and contracting activities over time.
Identifying large suppliers
To identify large suppliers, your agency should make informed estimates based on supplier profiles and financial disclosures. This may require you to review supplier data and leverage contract and invoicing records.
You should consider including an indicator or field in your contract management or finance system to identify large suppliers. This can help flag suppliers that may meet the large business definition.
When issuing Requests for Proposals (RFPs) or updating procurement documentation, you can ask your suppliers to self-report on whether they meet the large supplier definition. This proactive step may streamline your identification and ensure accuracy.
Reach out to your suppliers, address any invoice-specific requirements and ensure that all parties are aware of their obligations. The Ministry of Business, Innovation and Employment (MBIE) provides regular updates to large businesses in New Zealand via general awareness activities and outreach.
Resources
Comprehensive change management material is available elsewhere on our website. The Supplier onboarding guide also provides supplier engagement email templates specifically for government agencies communicating requirements to large suppliers.
Supplier onboarding: supplier engagement email templates for government agencies [DOCX, 521 KB]
We hold webinars for government agencies and their suppliers, which help clarify eInvoicing processes and answer implementation questions. We also host the quarterly Procure to Pay Community of Practice which is a collaborative forum to share notes with peers across government.
Procure to Pay Community of Practice
Managing your suppliers
Key messages
Your contract or procurement people can draw on the following key messages when engaging with large suppliers, to encourage them to meet the Rules.
Key Messages for Account Managers (Contract or Procurement Managers)
What to do if a supplier is not ready by the deadline
Sign up, to stay ahead
If you’re a business owner, accountant, business advisor or manager – or you just want to stay in front of the eInvoicing curve – sign up here for email updates, seminar/webinar invitations, and tips to get maximum value from eInvoicing.