Briefing document & Podcast: Singapore’s E-Invoicing & E-Reporting Mandate (InvoiceNow)

SUMMARY

Executive Summary:

Singapore is implementing a phased mandatory e-invoicing and e-reporting system called InvoiceNow for GST-registered businesses, built on the Peppol standard. The initiative, spearheaded by the Inland Revenue Authority of Singapore (IRAS), aims to improve GST compliance, streamline tax administration, and improve data accuracy. The rollout begins in November 2025, initially targeting new voluntary GST registrants, with plans to eventually encompass all GST-registered businesses. Compliance involves transmitting invoice data electronically to IRAS via the InvoiceNow network using a standardized XML format. Businesses must use approved Access Points (APs) or InvoiceNow-ready software. Failure to comply, especially for new voluntary registrants, may result in denial or revocation of GST registration.

Key Themes and Ideas:

• Mandate and Timeline: The GST InvoiceNow requirement will be introduced in phases, starting with a “soft launch” in May 2025 for voluntary early adoption.
  • November 1, 2025: Mandatory for newly incorporated companies voluntarily registering for GST.
  • April 1, 2026: Mandatory for all new voluntary GST registrants.
  • Future Expansion: The mandate will progressively extend to other GST-registered businesses, including new compulsory registrants and eventually all existing GST-registered businesses. B2B transactions are the current focus.
• Taxable Persons in Scope: The mandate primarily targets GST-registered businesses, specifically those registering voluntarily during the initial phases.
  • “From Nov 2025 and Apr 2026 as outlined above, any business that voluntarily registers for GST in Singapore will be required to comply with e-invoicing requirements at the time of registration.”
  • Exemptions exist for certain registrants, such as “overseas or special scheme registrants” like those under the Overseas Vendor Registration (OVR) regime and businesses registered solely due to Reverse Charge obligations.
• Scope of Transactions: Most transactions reportable in the GST return must be transmitted via InvoiceNow.
  • This includes standard-rated, zero-rated, and even certain exempt supplies (e.g., lease/sale of residential property, local sales of investment-grade precious metals). Standard-rated purchases must also be reported.
  • Exclusions apply to “deemed supplies,” “reverse-charge supplies,” “non-reportable purchases” (blocked input tax), exempt financial service transactions, and internal transfers with overseas related parties.
  • “all GST-reportable invoices must be sent except those relating to reverse charge, purely exempt supplies like financial services, deemed supplies with no actual invoice, and other out-of-scope or non-GST items.”
• Data Requirements: E-invoices must include comprehensive data elements.
  • “Key required fields include: Parties’ details… Invoice specifics… Line-item details… Tax amounts… Currency and values… Special indicators.”
  • Specific data points include supplier and customer details (name, GST registration number), invoice number and date, item descriptions, tax categories, and GST amounts.
• Transmission Method and Format: The system leverages the Peppol network, using a standardized XML invoice format.
  • “All data is transmitted through InvoiceNow , which is Singapore’s Peppol-based e-invoicing framework.”
  • Businesses use IMDA-accredited Access Points (APs) or approved InvoiceNow-ready accounting software to connect to the Peppol network.
  • The acceptable formats are Peppol BIS Billing 3.0 XML and PINT-SG (Peppol International, Singapore). PINT-SG will become the exclusive format from 2025 onward.
  • E-invoicing is direct transmission to the buyer. E-reporting is required if the buyer isn’t on the network.
• Due Dates for Data Submission: Invoice data must be submitted by the time of the GST return.
  • “the deadline to transmit invoice data is the earlier of: (a) the date you actually file the relevant GST return, or (b) the official due date for filing that GST return.”
  • While real-time submission isn’t mandated, IRAS encourages frequent submission.
• Penalties for Non-Compliance: Compliance is enforced.
  • “If a business that is required to use InvoiceNow does not comply, IRAS may refuse to approve its GST registration application, or revoke its GST registration after approval.”
  • IRAS will take a “calibrated (lenient) enforcement approach in the initial phase” for “genuine mistakes or errors”.
  • However, “once the system is fully in force, failing to transmit required invoices would constitute non-compliance with GST requirements.”
• Pre-Filled GST Returns: There are no provisions for pre-filled GST returns currently. Businesses must continue to file their GST returns (GST F5/F7) and maintain business records. The e-invoice data will support tax administration but not replace regular GST filings.

Considerations:

• Businesses should review IRAS guidance and FAQs, and the IMDA InvoiceNow Technical Handbook.
• Early preparation is encouraged as Singapore moves toward full digital invoicing.
• Businesses should choose InvoiceNow-compatible software or Access Point services.

This briefing provides a high-level overview. Businesses should consult the official IRAS resources for complete and up-to-date information.

INDPETH ANALYSIS

• Implementation Timeline: A phased implementation has been announced: [tungstenau…mation.com]
  • 1 May 2025 – Soft Launch: Voluntary early adoption begins. From this date, any GST-registered business may start transmitting e-invoices to IRAS via InvoiceNow on a voluntary basis (IRAS actively encourages early adopters). [iras.gov.sg], [tungstenau…mation.com]
  • 1 November 2025 – First Mandatory Phase: Newly incorporated companies voluntarily registering for GST (within 6 months of incorporation) must comply from this date. In other words, any business that is newly formed and opts into GST registration within 6 months will be required to use InvoiceNow to send its invoice data to IRAS upon GST registration. [iras.gov.sg], [iras.gov.sg]
  • 1 April 2026 – Extended Mandatory Phase: All new voluntary GST registrants (regardless of incorporation date) must comply from this point onward. Any business applying for voluntary GST registration on or after 1 Apr 2026 is required to adopt InvoiceNow for e-invoicing and data transmission as a condition of registration. [iras.gov.sg], [iras.gov.sg]
  • Future Expansion: After these initial phases, IRAS plans to progressively extend the mandate to other GST-registered businesses – including new compulsory registrants (businesses that must register due to exceeding the GST turnover threshold) and eventually all existing GST-registered businesses. These later phases are still under consultation; further details and dates will be announced once determined. (Notably, B2B transactions are the current focus; B2G e-invoicing is not yet mandatory but the government intends to include public sector invoicing in the future.) [iras.gov.sg], [ey.com] [tjc-group.com], [sovos.com]
• Taxable Persons in Scope: Initially, this mandate targets GST-registered businesses, specifically those registering on a voluntary basis in the rollout phase. Key points on who must comply:
  • In-Scope (Phased): From Nov 2025 and Apr 2026 as outlined above, any business that voluntarily registers for GST in Singapore will be required to comply with e-invoicing requirements at the time of registration. (During GST registration, such businesses must obtain a Peppol InvoiceNow ID and be ready to transmit invoices as part of the approval process.) Over time, all GST-registered companies – including those mandatorily registered due to turnover – are expected to come into scope once the mandate expands in later phases. [iras.gov.sg] [ey.com], [cleartax.com]
  • Excluded Entities: Certain GST registrants are explicitly exempted from the InvoiceNow mandate for now. IRAS has carved out overseas or special scheme registrants: e.g. overseas-based entities registered under the Overseas Vendor Registration (OVR) regime (for remote services or low-value goods) and businesses registered solely due to Reverse Charge obligations are excluded from the mandate. These categories do not need to adopt InvoiceNow at this stage. (In practice, this means overseas vendors and pay-only OVR suppliers, as well as entities with only reverse-charged GST, are not required to transmit invoices via IRAS’s system.) [iras.gov.sg], [ey.com]
• Scope of Transactions (What must be reported): Businesses in scope must transmit invoice data for virtually all transactions that are reportable in the GST return, with only a few exceptions. In effect, IRAS requires that all sales and purchase transactions relevant to GST reporting be electronically reported via InvoiceNow. Key inclusions and exclusions:
  • Transactions to be Transmitted (Included): This covers most invoiced business dealings: standard-rated supplies (sales of goods/services subject to GST at 8%), zero-rated supplies (exports of goods and international services taxed at 0%), and even certain exempt supplies. Notably, sales of exempt goods/services like the lease or sale of residential property and local sales of investment-grade precious metals – which are exempt from GST – are within scope and must be reported if they appear on the GST return. On the purchase side, standard-rated purchases (local purchases on which you can claim input GST) must be reported as well. In practice, this means any purchase where the business intends to claim input tax (including imports of goods with GST-paid import permits, and other taxable purchases) needs its invoice data sent to IRAS. (There is even mention of capturing “zero-rated purchases” such as goods acquired for subsequent export, though such cases typically involve import GST or are out-of-scope – broadly, if a purchase or expense is reported in the GST return, its details should be transmitted.) For high-volume retail sales or petty cash purchases, IRAS allows aggregation: businesses can compile multiple small transactions (e.g. point-of-sale receipts, cash expenses) and send them as periodic summary entries rather than individual invoices. [cleartax.com] [ey.com]
  • Excluded Transactions: The mandate does not apply to certain special or non-standard transactions, mainly those where no true “tax invoice” is issued or needed. For example, deemed supplies (transactions treated as supplies for GST purposes even without a sale, such as free samples or private use of business assets) do not have to be reported via InvoiceNow. Reverse-charge supplies are also excluded – i.e. purchases of services or imported goods where the business itself must account for GST (these are accounted via reverse charge in the GST return, so no supplier invoice to transmit). IRAS also excludes “non-reportable” purchases like items with blocked input tax (e.g. certain expenses where GST isn’t claimable – since these don’t get reported as input tax, their invoices need not be sent). Moreover, entire categories of exempt sales such as financial services are carved out – exempt financial service transactions (and certain digital payment token transactions) are not required to be transmitted under InvoiceNow. Finally, transactions involving internal transfers with overseas related parties are excluded: e.g. goods or services provided by an overseas head office to its Singapore branch (which might be recorded for accounting but are outside the scope of local GST) do not need to be transmitted. In short, all GST-reportable invoices must be sent except those relating to reverse charge, purely exempt supplies like financial services, deemed supplies with no actual invoice, and other out-of-scope or non-GST items. [cleartax.com] [vatabout.com] [vatabout.com], [ey.com]
• Data Requirements (Content of e-Invoices/E-Reports): When transmitting an invoice via InvoiceNow, businesses must include a comprehensive set of mandatory data elements as specified by IRAS. The e-invoice effectively mirrors a full tax invoice in structured digital form. Key required fields include:
  • Parties’ details: Full identification of the supplier and customer, notably each party’s name and GST registration number (or Unique Entity Number, UEN). The system uses these to validate GST-registrant status and route the invoice. [cleartax.com], [vatabout.com]
  • Invoice specifics: The invoice number (unique identifier), invoice date, and a universal invoice UUID must be provided for traceability. If the invoice is a debit note or credit note, those are reported similarly with references to the original invoice. [cleartax.com]
  • Line-item details: A breakdown of goods or services supplied, including descriptions, quantity, unit price, etc., as would appear on a normal invoice. Each line item’s tax category must be specified – for example, standard-rated (“SR”), zero-rated, exempt, etc., using IRAS’s standardized GST codes. Businesses need to map their internal tax codes to these official categories (IRAS provides a code list in its guide). [cleartax.com]
  • Tax amounts: The invoice data must clearly state the GST amount for each taxable line (or note if no GST for zero/exempt lines) and the totals. Precise GST totals and the applicable tax rate or code per line are required so IRAS can reconcile figures. [cleartax.com], [vatabout.com]
  • Currency and values: If an invoice is issued in a foreign currency, the data must include the currency code and the converted amounts in Singapore dollars (using IRAS-approved exchange rates) for GST purposes. [cleartax.com]
  • Special indicators: For aggregated entries (like a monthly total of many cash sales), businesses should use indicators such as “POS” (Point-of-Sale) or “PCP” (petty cash purchases) in the description or invoice fields to denote that the entry represents a bundle of transactions. This ensures clarity on what the transmitted “invoice” represents.
    In summary, the data submitted is essentially a full electronic tax invoice. The IRAS e-Tax Guide provides the complete list of required data fields to be included. Businesses must use an InvoiceNow-compatible software or Access Point service that automatically formats these fields correctly (e.g. ensuring the correct XML tags for each data element). [cleartax.com]
• Transmission Method and Format: Singapore’s system leverages the Peppol network for both e-invoicing and e-reporting, meaning the technical format is a standardized XML invoice. Key points:
  • InvoiceNow Network (Peppol) – All data is transmitted through InvoiceNow, which is Singapore’s Peppol-based e-invoicing framework. Businesses must use an IMDA-accredited Access Point (AP) or an approved InvoiceNow-ready accounting software (which connects to an AP) to send and receive e-invoices. The APs route invoices between trading parties and also forward a copy to IRAS. This model is often described as a “5-corner” model (supplier, buyer, and IRAS as an additional recipient via the network). [iras.gov.sg] [sovos.com]
  • Peppol BIS 3.0 / PINT Formats – The content format of Singapore e-invoices is based on the Peppol Business Interoperability Specification. Initially, Singapore adopted Peppol BIS Billing 3.0, with slight localization to handle GST instead of VAT. More recently, IMDA introduced a Singapore Peppol InvoiceNow specification called “PINT‐SG” (Peppol International, Singapore), a streamlined format. Both BIS 3.0 XML and PINT-SG are currently accepted, but from 2025 onward PINT-SG will become the exclusive format for InvoiceNow transmissions. In practice, this means service providers and software in Singapore are updating to ensure all e-invoices use the PINT-SG standard schema going forward. [theinvoicinghub.com], [theinvoicinghub.com] [sovos.com], [theinvoicinghub.com]
  • E-Invoice vs E-Report: If both supplier and buyer are on InvoiceNow, the invoice is delivered electronically to the buyer and simultaneously reported to IRAS. However, if an invoice is issued to a customer not on the network (or it’s a consumer sale with no e-invoice delivery), the business still must send the invoice data to IRAS – effectively performing e-reporting of that transaction. In such cases, the data can be transmitted through the same Access Point infrastructure directly to IRAS’s system (with IRAS acting as the recipient). In essence, whether or not an actual e-invoice is sent to the customer, any in-scope transaction must be recorded in the Peppol format and submitted to IRAS. This can be done in real time or in batches. IRAS’s system supports batch submissions (up to 10 invoices per API call, or 10MB of data) for efficiency. [cleartax.com]
  • Other Formats: It’s important to note that traditional invoicing methods are still allowed between trading parties in Singapore as of now. There is no full mandate that all invoices must be in Peppol form to the customer. Companies may still issue paper invoices or PDF invoices to their customers if mutually agreed, since e-invoicing is not yet universally compulsory. However, using those formats does not exempt the company from the reporting requirement – the invoice data must still be sent to IRAS via InvoiceNow. Over time, as more partners join the network, businesses will likely shift to sending Peppol e-invoices to customers as well, to avoid dual processes. (Also, many government agencies in Singapore already accept Peppol invoices, and a B2G mandate is anticipated in the future.) [theinvoicinghub.com], [theinvoicinghub.com] [theinvoicinghub.com] [tjc-group.com]
• Due Dates for Data Submission: Unlike some countries with immediate clearance models, Singapore’s approach ties e-invoice reporting to the GST filing cycle. Invoice data must be submitted by the time of the GST return for the period. Specifically, IRAS has stated that the deadline to transmit invoice data is the earlier of: (a) the date you actually file the relevant GST return, or (b) the official due date for filing that GST return. In practical terms, this means all in-scope invoices for a given accounting period must be sent to IRAS no later than the normal filing deadline (if you file early, that effectively becomes the deadline). For example, if a company files quarterly GST returns due one month after quarter-end, all invoices from that quarter should be transmitted by that due date at the latest. There is no requirement to send each invoice in real time to IRAS, as long as everything is reported by the return deadline. However, IRAS encourages more frequent or prompt submission. In fact, when using InvoiceNow to issue invoices to customers, the data reaches IRAS immediately (real-time) by design. For invoices not sent in real-time (e.g. accumulated consumer sales or invoices to offline customers), businesses are urged to submit regularly (e.g. weekly) rather than waiting until the last minute. This helps ensure smooth compliance and gives time to correct any errors. (IRAS provided examples in its guidelines for special cases like advance billing or post-cancellation submissions, but generally aligning transmission with your GST filing cycle is the rule.) [cleartax.com], [vatabout.com] [sovos.com] [cleartax.com]
• Penalties for Non-Compliance: The e-invoicing mandate is backed by law/policy, and there are consequences for failing to comply, especially for those for whom it’s a condition of GST registration. Key points:
  • Impact on GST Registration: For new voluntary registrants, compliance with InvoiceNow is effectively part of the registration approval. If a business that is required to use InvoiceNow does not comply, IRAS may refuse to approve its GST registration application, or revoke its GST registration after approval. In other words, adopting e-invoicing is mandatory to obtain/keep GST-registered status in those phases – a serious incentive to comply. [iras.gov.sg]
  • Enforcement Stance: IRAS has indicated it will adopt a calibrated (lenient) enforcement approach in the initial phase. Especially during the onboarding period, IRAS will not harshly penalize businesses for genuine mistakes or errors in the invoice submissions, as long as the businesses are making reasonable efforts and maintaining proper records. Minor discrepancies between the transmitted data and the GST return, for example, won’t incur penalties if the company can substantiate its figures and wasn’t negligent. This “grace period” approach is to facilitate adoption. [iras.gov.sg], [iras.gov.sg] [iras.gov.sg]
  • Penalties for Continued Non-Compliance: Ultimately, once the system is fully in force, failing to transmit required invoices would constitute non-compliance with GST requirements. While specific fines are not yet detailed in public materials, such non-compliance would likely be subject to penalties under the GST Act (similar to failing to keep proper records or filing incorrect returns). The most immediate risk, however, is loss of GST registration as noted above. As the mandate expands, we can expect IRAS to enforce compliance more strictly. Businesses cannot opt out of the requirement (aside from the officially excluded categories); all in-scope GST taxpayers will be expected to use the e-invoicing system going forward. [iras.gov.sg]
• Pre-Filled GST Returns: One common question is whether IRAS will use the e-invoice data to pre-fill or auto-populate GST returns for businesses. As of now, there is no provision for pre-filled GST returns in Singapore’s system. IRAS has made it clear that the InvoiceNow data submission is in addition to (not a replacement for) regular GST filings – GST-registered businesses must continue to file their GST returns (GST F5/F7) on schedule and maintain the usual business records. The transmitted invoice data will support tax administration (e.g. allowing IRAS to cross-check declarations, speed up refund audits, etc.), but taxpayers still need to compile and file their GST return figures manually or via their accounting systems. In the future, once a large share of transactions are flowing through IRAS, it’s conceivable that IRAS might introduce services to assist in return preparation (for example, providing a summary of the sales/purchases reported via InvoiceNow). However, at this point IRAS has not announced any automated pre-filling of GST returns based on the e-invoice data, and businesses remain responsible for accurate GST reporting in their returns. (In short, the e-invoicing mandate is aimed at improving compliance and data accuracy, but you still have to file your GST returns as before, rather than the government sending you a pre-completed return.) [iras.gov.sg]

• IRAS – “GST InvoiceNow Requirement” (official e-invoicing mandate details) [iras.gov.sg], [iras.gov.sg]
• IRAS e-Tax Guide & FAQs (Mar 2025) [ey.com], [iras.gov.sg]
• VATabout News (Mar 2025) – Summary of IRAS E-Invoicing Guidelines [vatabout.com], [vatabout.com]
• ClearTax Singapore (Mar 2025) – Guide to E-Invoicing in SG [cleartax.com], [cleartax.com]
• Sovos (2025) – Continuous Transaction Controls in Singapore [sovos.com], [sovos.com]
• The Invoicing Hub (Jun 2025) – E-Invoicing Compliance in Singapore. [theinvoicinghub.com], [theinvoicinghub.com]

• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Collection of E-Invoicing Guides – Worldwide – VATupdate
  • Briefing / Comprehensive Guides (incl. podcasts)

• Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE