Briefing document & Podcast: Australia E-Invoicing and E-Reporting

SUMMARY

Executive Summary:

Australia is adopting e-invoicing through the Peppol network, with a phased approach. Currently, e-invoicing is mandated for Business-to-Government (B2G) transactions involving federal government entities. While a Business E-Invoicing Right (BER) framework was proposed for Business-to-Business (B2B) transactions, it hasn’t been made compulsory; the focus has shifted toward encouragement and voluntary adoption. The Australian Taxation Office (ATO) acts as the Peppol Authority but doesn’t receive or read individual invoices, relying on Business Activity Statements (BAS) for GST reporting. Businesses are encouraged to adopt e-invoicing for efficiency and compliance with trading partner requests. The current standard is Peppol PINT A-NZ, transitioning from Peppol BIS Billing 3.0.

Key Themes and Ideas:

1. Phased Implementation and Voluntary B2B Adoption:

• Australia has adopted e-invoicing, using the Peppol network as the standard. The implementation has been gradual.
• As of July 1, 2022, all federal Commonwealth government agencies were mandated to be able to receive e-invoices from suppliers (B2G mandate).
• A proposed phased Business E-Invoicing Right (BER) for B2B transactions, which would have allowed companies to require their trading partners to send e-invoices via Peppol, has not been enforced.
  • “However, the current government has not enforced these proposed mandates – the BER framework was not made compulsory and instead the approach shifted to encouragement and voluntary adoption.”
• The government confirmed that e-invoicing will become the default for Commonwealth procurement. They allocated funding to support the Peppol e-invoicing network and announced interim targets: e.g. federal agencies should process at least 30% of invoices via e-invoicing by July 1, 2026, and be able to automate sending e-invoices by December 2026.

2. The Peppol Network and the 4-Corner Model:

• Australia uses the 4-corner Peppol e-invoicing model, which includes the supplier, their Access Point provider, the buyer, and their Access Point provider.
• E-invoices are transmitted through these access points, ensuring secure delivery from the supplier’s system to the buyer’s system.
• The ATO acts as the Peppol Authority in Australia, overseeing and regulating the network.
  • “E-invoices are transmitted through Peppol Access Point providers – each trading entity uses an access point service to send/receive invoices. There is no central government invoice platform collecting these invoices; instead, the Peppol network relays the invoice from the supplier’s system to the buyer’s system securely.”

3. Data Requirements and Formats:

• E-invoices must contain all the information required of a standard tax invoice under Australian GST law, in a structured digital format.
• Key data fields include supplier details (legal name, address, ABN), customer details (name, address, ABN if applicable), invoice information (date, unique number), line item details (description, quantity, unit price), tax (GST amount), and totals (subtotal, GST, total gross amount).
• Australia requires using the Peppol PINT (Pan-European Public Procurement Online International Invoice) specification for the e-invoice content format, specifically the A-NZ PINT variation developed jointly with New Zealand. This transition was completed in May 2025.
  • “From 15 November 2024, the PINT A-NZ specification (an Australia/New Zealand adaptation of Peppol’s international invoice format) became the preferred format, and by 15 May 2025 it is the only supported format for e-invoice exchange on the network.”

4. No Real-Time Reporting to the ATO:

• Australia’s e-invoicing system doesn’t involve real-time reporting of invoices to the ATO.
• GST is reported through periodic Business Activity Statements (BAS), where businesses compile sales and purchase figures.
  • “All invoice data in an e-invoice is shared only between supplier and buyer via the Peppol network, not directly with the Tax Office.”
  • “Australia does not require businesses to transmit invoice data to the tax authority on issuance. All necessary tax reporting is done via periodic activity statements, not invoice-by-invoice uploads.”

5. Scope of Transactions and Taxable Persons:

• The e-invoicing requirements currently apply to domestic transactions, particularly involving government (B2G).
• Domestic B2B transactions are voluntary except when a trading partner exercises the right to request e-invoices (per the BER framework, which is also voluntary).
• International transactions are not specifically subject to an e-invoicing mandate.
• Foreign companies without an Australian presence or ABN are not directly obligated under Australia’s e-invoicing rules.
  • “The e-invoicing requirements in Australia currently apply to domestic transactions, particularly involving government…International transactions (import/export) are not specifically subject to any e-invoicing mandate in Australia.”

6. Archiving Requirements:

• Australia requires businesses to retain invoices and records for 5 years, including e-invoices. Certain records must be kept for 7 years.
• Electronic archiving is allowed, but the archives must be readable and accessible on request by authorities.
  • “Australia’s tax law requires businesses to retain invoices and records for 5 years, and this applies equally to e-invoices. Electronic archiving is allowed…The archives, however, must be readable and accessible on request by authorities.”

7. Penalties for Non-Compliance:

• Currently, there are no specific fines or penalties solely for not using e-invoicing in B2B transactions.
• However, failing to send an e-invoice upon a trading partner’s request, ignoring government requirements, or not following normal tax invoice rules can lead to commercial disputes, payment delays, or penalties under existing GST law. In the B2G context, non-compliance may cause payment delays or lost opportunities.
  • “Currently, there are no specific fines or penalties solely for not using e‑Invoicing in B2B transactions, because it’s not universally mandated yet.”
  • “If a supplier were to ignore the mandate or a government agency’s requirement for e-invoicing, the main “penalty” is practical – the invoice might not be accepted or processed as quickly.”

INDEPTH ANALYSIS

• 2019–2022: Australia adopted the Peppol framework in 2019, and from 1 July 2022, all federal Commonwealth government agencies (Non-Corporate Commonwealth Entities) were mandated to be able to receive e‑Invoices from suppliers. This B2G mandate means agencies must accept invoices in the Peppol format and pay them within 5 days under the government’s “Pay on Time or Pay Interest” policy. (At this stage, e-invoicing for businesses remained voluntary.) [sovos.com], [edicomgroup.com] [avalara.com], [avalara.com]
• Planned B2B Phases (2023–2025): The government initially proposed a phased Business E‑Invoicing Right (BER) for B2B transactions. This would have allowed companies to require their trading partners to send e‑Invoices via Peppol, rolling out by company size – e.g. large businesses by July 2023, medium by July 2024, and all businesses (including small firms) by 1 July 2025. In effect, by 2025 any Australian business could insist on receiving e-invoices, and trading partners would be obliged to comply. However, the current government has not enforced these proposed mandates – the BER framework was not made compulsory and instead the approach shifted to encouragement and voluntary adoption. (Businesses are strongly encouraged to use Peppol e-invoicing on their own terms, and many large/medium companies have begun doing so.) [comarch.com], [spaceinvoices.com] [sovos.com]
• 2024–2025 Updates: As of the 2024–25 federal Budget, the focus is on the public sector leading by example. The government confirmed that e‑Invoicing will become the default for Commonwealth procurement (all federal agencies). It allocated funding to support the Peppol e-invoicing network and announced interim targets: e.g. federal agencies should process at least 30% of invoices via e‑Invoicing by 1 July 2026, and be able to automate sending e-invoices by Dec 2026. Many state and territory governments are also onboard – for instance, NSW, SA, ACT, TAS, VIC have enabled receipt of e-invoices in most agencies, and others (e.g. WA, QLD) are piloting or developing e-invoicing capabilities. There is no nationwide B2B mandate date yet (outside of the voluntary BER framework), but the broad expectation is to continue increasing adoption, potentially paving the way for future mandates. Meanwhile, technical standards have been updated (see “Format” below), and from 15 Nov 2024 Australia moved to a new standard invoice format as part of Peppol adoption. [comarch.com] [ato.gov.au] [edicomgroup.com] [sovos.com], [edicomgroup.com]

• Government agencies: All federal government departments (NCEs) must comply with e-invoicing policies (able to receive and process Peppol invoices). Many state/local government bodies are also voluntarily adopting these standards. [sovos.com] [edicomgroup.com]
• Australian businesses (established in-country): Any business with an Australian Business Number (ABN) can participate in e-invoicing. Under the (voluntary) BER framework, all Australian businesses were slated to be in scope by 1 July 2025 for the right-of-request (i.e. if an Australian trading partner asks for a Peppol e-invoice, the business must comply). In practice, as of late 2025, large and mid-size companies are already expected to comply with such requests, and smaller businesses are encouraged to be ready. There is no current law compelling every business to issue e-invoices unilaterally, but readiness is effectively expected across the economy. [spaceinvoices.com]
• Non-established / Foreign businesses: Foreign companies without an Australian presence or ABN are not directly obligated under Australia’s e-invoicing rules. If a foreign supplier has to invoice an Australian government agency or business, they can use Peppol e-invoicing (and may need to use an identifier like an ABN or another Peppol ID), but there is no legal mandate forcing overseas companies to use Australian e-invoicing standards. (Foreign businesses selling into Australia still must follow GST registration rules if over the threshold, and issue tax invoices for GST purposes, but these can be in any agreed format – paper or electronic.) [avalara.com] [spaceinvoices.com], [spaceinvoices.com]

• Supplier details: legal name, address, and ABN (Australian Business Number) of the issuer. If the supplier is GST-registered, an ABN is mandatory on invoices.
• Customer details: name and address of the buyer; if the buyer is a business, their ABN or ACN (company number) should appear.
• Invoice information: invoice issue date and a unique invoice number. (Australian tax invoices must be issued within a reasonable time – generally, if a buyer requests an invoice, it must be provided within 28 days of the request.) [spaceinvoices.com]
• Line item details: description of goods or services supplied, quantity, unit price, and line totals.
• Tax and totals: the amount of GST (Goods and Services Tax) applied, with a breakdown: typically a 10% GST on taxable supplies. The invoice should show the subtotal (ex GST), the GST amount, and the total gross amount including GST. It should also indicate if any line items are GST-free (e.g. exports or certain exempt items). [spaceinvoices.com]
• Other mandatory content: payment terms or due date, and any required statements (for example, a declaration of authenticity or other notes mandated by regulation). Australian tax invoices above certain thresholds must state “Tax Invoice” and include the buyer’s identity/ABN if the sale is over $1,000 AUD. (These are standard GST invoice rules.)
• Format and structure: When sent as a Peppol e-invoice, this data is packaged in a structured XML format (UBL schema via Peppol). As of Nov 2024, Australia requires using the Peppol PINT (Pan-European Public Procurement Online International Invoice) specification for the e-invoice content format, specifically the A-NZ PINT variation developed jointly with New Zealand. This ensures all required fields (like those above) are present in a standardized way. [sovos.com], [edicomgroup.com]

• E-Invoice format: The standard for Australian e-invoices is Peppol BIS Billing 3.0, transitioning to the Peppol PINT format. From 15 November 2024, the PINT A-NZ specification (an Australia/New Zealand adaptation of Peppol’s international invoice format) became the preferred format, and by 15 May 2025 it is the only supported format for e-invoice exchange on the network. In practice, this means e-invoices are sent as structured XML documents conforming to that schema. (Australia’s and NZ’s Peppol authorities coordinated this format upgrade to unify standards.) This format encapsulates all invoice details (supplier, buyer, line items, tax, etc.) in a machine-readable form. Invoices and credit notes must be exchanged in this format via Peppol Access Points. [edicomgroup.com]
• Transmission method: E-invoices are transmitted through Peppol Access Point providers – each trading entity uses an access point service to send/receive invoices. There is no central government invoice platform collecting these invoices; instead, the Peppol network relays the invoice from the supplier’s system to the buyer’s system securely. The Australian Taxation Office (ATO) acts as the Peppol Authority to oversee and regulate the network, but the ATO does not receive or read each invoice. This is an important distinction from some countries: Australia’s model is often called a “post-audit” model of e-invoicing, meaning invoices flow business-to-business and can be audited later, rather than being cleared by tax authorities in real time. [edicomgroup.com] [sovos.com]
• E-Reporting: Because of the above model, there is currently no separate “e-reporting” system for invoices in Australia. Unlike jurisdictions with continuous transaction controls or real-time clearance, Australia does not require businesses to transmit invoice data to the tax authority on issuance. All necessary tax reporting is done via periodic activity statements, not invoice-by-invoice uploads. As such, there is no specific format for e-reporting of invoice data – the concept doesn’t apply under the present system (businesses simply exchange Peppol e-invoices with each other, and maintain their records for tax time). [avalara.com]

• Invoice issuance: Businesses must issue tax invoices within a timely manner. If an Australian business customer requests a tax invoice (for GST purposes), the supplier is legally required to provide it within 28 days of the request. In practice, most invoices are issued at the time of supply or shortly after. E-invoices sent via Peppol are delivered almost instantly once issued, but there is no government-imposed max time (aside from the 28-day rule to fulfill a request). [spaceinvoices.com]
• E-invoice exchange: When using the Peppol network, sending an invoice is effectively immediate – there is no grace period like “X days after issuance” because the invoice goes directly to the buyer’s system as soon as the supplier sends it. The buyer is expected to process/pay it promptly (especially government buyers, who must pay within 5 days as noted). There is no requirement to separately send the invoice data to the ATO at any point. [avalara.com]
• Periodic tax reporting: Australian businesses report sales and GST through periodic returns (the Business Activity Statement, BAS). GST reporting deadlines depend on size: large companies file monthly (due by the 21st of the following month), smaller companies typically file quarterly (due by the 28th of the month after the quarter). These BAS filings are the mechanism by which invoice data (in aggregate) reaches the tax authority. So, effectively, the “deadline” for reporting invoice information (for tax purposes) is the BAS due date – at that time, businesses must have accounted for all invoices of the period in their GST return. There is no separate, transaction-level deadline like “submit each invoice within X days” to the tax office, since Australia has no continuous e-invoice reporting mandate. [spaceinvoices.com] [avalara.com]

• Business-to-Government: If a supplier were to ignore the mandate or a government agency’s requirement for e-invoicing, the main “penalty” is practical – the invoice might not be accepted or processed as quickly. In fact, federal agencies are obligated to pay e-invoices within 5 days, but only if they receive the invoice via Peppol. A supplier who fails to use e-invoicing for a government client could face payment delays or even run afoul of contract terms. Moreover, as e-invoicing becomes the default in procurement, businesses that cannot comply may risk losing government contracts or opportunities. (In short, non-compliance in the B2G context can hurt your ability to do business with government, even if there isn’t a direct monetary fine.) [avalara.com]
• Business-to-Business: Under the proposed BER rules, failing to send an e-invoice upon a trading partner’s request could potentially be viewed as non-compliance with the intended regulations. While there isn’t a defined fine (since BER isn’t a formal law with penalties yet), it’s likely that over time not complying could lead to commercial disputes or regulatory pressure. The government had considered empowering agencies (possibly the ACCC) to enforce the right to e-invoice if needed. For now, though, there’s no dedicated e-invoicing police or fines for B2B – compliance is driven by business benefit and peer pressure rather than legal penalty. [avalara.com]
• General tax compliance penalties: It’s important to note that all normal tax invoice rules and record-keeping laws still apply. If a business fails to issue proper tax invoices or to report sales in its BAS, the ATO can impose penalties under existing GST law. For example, not keeping required records or not providing invoices when required can result in fines per the Tax Administration Act. Also, if a business were to deliberately avoid using e-invoicing to hide sales (tax evasion), general anti-fraud penalties would apply. But these are not penalties for e-invoicing itself; they are for underlying tax obligations. In summary, no new e-invoicing-specific fines exist as of 2025, aside from the contractual and tax implications noted. [avalara.com]

• Minimum retention period: Generally, 5 years from the date of the transaction (or the filing of the tax return relating to that transaction) is the standard retention period for invoices in Australia. This covers both sales and purchase invoices. [basware.com]
• Extended retention: Certain records may effectively need to be kept for 7 years – for example, some sources note that if an invoice relates to a longer-term transaction (like a multi-year contract or capital purchase), it might be wise or required to keep it for 7 years. (Australian corporations law can also require 7-year record retention in some cases.) To be safe, many companies align with the longer period for important documents. [basware.com]
• Format of storage: Invoices can be stored digitally (scanned or in original electronic form). There is no requirement to keep paper copies of e-invoices. The archives, however, must be readable and accessible on request by authorities. This means businesses should ensure their e-invoices can be rendered in human-readable form (for example, a PDF or print-out) for compliance checks. [basware.com]
• Location of storage: Storing invoice data abroad (overseas servers) is permitted as long as the records can be made available to Australian tax officers and kept secure. Many businesses use cloud services or their Peppol service provider’s archive solutions for convenience. [basware.com]
• Authenticity and integrity: Although Australia doesn’t mandate digital signatures on e-invoices, it’s implied that the Peppol network’s security plus normal record-keeping practices suffice to ensure an invoice’s authenticity and integrity. Businesses should maintain systems that prevent alteration of archived invoices. (Using an accredited Peppol Access Point and proper system logs helps with this.) Notably, one compliance method for integrity is the use of an Advanced Electronic Signature, which some e-invoice solutions support, though this is not explicitly required by law – it’s one way to meet integrity requirements if needed. [comarch.com]

• Some countries with mandatory e-invoice reporting use that data to pre-fill tax declarations, but Australia’s model is different. The ATO only receives summary data when you file your BAS (e.g. total sales, total GST collected, etc.), not the individual invoices beforehand. Therefore, the onus is on businesses to ensure their BAS is accurate. [sovos.com]
• There have been discussions about leveraging digital invoice data for efficiency (for instance, to streamline compliance or maybe one day offer “push” tax returns), but as of the latest updates (2025), no such system is in place. Every registered business must review and submit its own GST returns. The benefit of e-invoicing is mainly operational (less manual entry, fewer errors, faster payments), rather than automatic tax filing.
• Note: Businesses using accounting software integrated with e-invoicing will find it easier to prepare BAS returns because their systems have all the invoice data in one place. However, this is not an official pre-filling by the tax authority – it’s just the business’s internal automation.

• Australian Taxation Office (ATO) – eInvoicing: The ATO’s website provides detailed guidance on Peppol e-invoicing and lists of enabled agencies. (The ATO is the local Peppol Authority overseeing standards.) The ATO also publishes news updates – for example, confirming the 2024–25 Budget measure establishing e-invoicing as default for government procurement. [sovos.com] [comarch.com]
• Legislation: Enabling legislation was passed to allow e-invoicing rollout (e.g. amendments empowering the ATO to act as Peppol Authority in 2019). There isn’t yet a dedicated “E-Invoicing Act” for B2B. However, related laws include the Payment Times Reporting Act 2020 (which indirectly encouraged e-invoicing to improve payment times) and existing GST law (tax invoice requirements in A New Tax System (Goods and Services Tax) Act 1999). No specific regulation mandating private-sector e-invoicing has been enacted as of 2025 – mandates are via policy for government and would-be via legislative instrument for BER if implemented. [ato.gov.au]
• Government Publications: The federal government’s announcements and budget papers in 2022 and 2024 outline the e-invoicing plans. Also, a joint Australia–New Zealand initiative (under the Australia/New Zealand Electronic Invoicing Arrangement 2018) set the stage for adopting Peppol. Official information confirms technical standards like the switch to PINT format and the requirement for agencies to pay e-invoices in 5 days. [edicomgroup.com], [comarch.com] [edicomgroup.com] [ato.gov.au]
• External Reports: Many accounting and consulting firms (Deloitte, Sovos, Avalara, etc.) and solution providers (Comarch, EDICOM, Basware) provide summaries of Australia’s e-invoicing compliance. These can be useful for interpretation. For instance, Avalara’s country guide and Sovos’ overview are consistent with ATO’s position that B2B e-invoicing is encouraged but not mandatory, and there are no real-time reporting obligations. Such external resources often cite or link to the ATO and government releases for verification. [avalara.com], [avalara.com]