Government agencies' requirements: large suppliers eInvoicing
From 1 January 2027, government agencies must ensure that large suppliers send eInvoices.
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In October 2025, the government announced the fifth edition of the Government Procurement Rules (“the Rules”). From 1 January 2027 government agencies, that must follow the Rules, will need to require large suppliers to send eInvoices, when contracting with them.
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.
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 or invoices
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.
Identifying large suppliers
To identify large suppliers, your agency will need to make informed estimates based on supplier profiles and financial disclosures. This may require you to collaborate with your IT and procurement teams, review existing supplier data, and leverage contract and invoicing records.
You should consider including an indicator or field in your contract management system to track supplier size. 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.
The Ministry of Business, Innovation and Employment (MBIE) regularly provides updates to large businesses in New Zealand via general awareness activities and outreach. These include known large suppliers to government. However, we encourage you to reach out to your suppliers, address any invoice-specific requirements and ensure that all parties are aware of their obligations.
Resources
Comprehensive change management material is available elsewhere on our website. This includes step-by-step guidance for supplier onboarding. This also includes template emails for use in communicating requirements to large suppliers.
We hold a number of webinars for government agencies and their suppliers, which can clarify eInvoicing processes and answer implementation questions. The quarterly Procure to Pay Community of Practice also lets you share notes with your peers.
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)
Responding to suppliers who aren’t ready by the deadline or requests for extensions
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.