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Iceland — E-Invoicing & E-Reporting Country Booklet

Click HERE for more episodes in ”Country Profiles on E-Invoicing, E-Reporting, E-Transport, SAF-T Mandates, and ViDA Initiatives”

 



Executive Summary

Iceland operates a delivery-based Peppol e-invoicing regime with no clearance or Continuous Transaction Controls (CTC). As a non-EU member state within the EEA/EFTA framework, it is exempt from the EU’s ViDA (VAT in the Digital Age) timetable and does not have mandatory B2B e-invoicing. Its advanced B2G (Business-to-Government) e-invoicing system, however, aligns with EU Directive 2014/55/EU.

The core principles are:

  • Mandatory B2G Acceptance: Public bodies are legally required to accept structured e-invoices compliant with EN 16931 / ÍST TS 236 (a national Peppol BIS Billing 3.0 CIUS) via the Peppol network. This creates a de facto mandate for suppliers to the public sector.
  • Voluntary B2B/B2C: E-invoicing between businesses and consumers is voluntary and driven by commercial agreement, with no mandated format or reporting.
  • Post-Audit VAT Control: VAT is administered by Skatturinn (Iceland Revenue and Customs) through periodic, self-prepared electronic returns. There is no transaction-level e-reporting, no SAF-T, and no pre-filled VAT returns. The tax authority is not involved in the real-time invoice flow.
  • ViDA Exemption: The EEA Agreement excludes taxation, meaning Iceland is not bound by EU VAT directives, including the ViDA package. Future B2B digital reporting would be an autonomous policy choice.
  1. Iceland’s E-Invoicing Model: Delivery-Based Peppol, No Clearance

Iceland’s e-invoicing strategy is characterized by its delivery-based model via the Peppol four-corner network, fundamentally differing from clearance or Continuous Transaction Control (CTC) systems seen in many other countries.

  • No Clearance/CTC: The sources explicitly state: “Iceland is not a Continuous Transaction Controls (CTC) or clearance country. It has no mandatory domestic B2B or B2G e-invoicing clearance regime and no mandatory continuous transaction reporting (CTR) system in force” [1]. The tax authority, Skatturinn, is “not in the transaction path” [2].
  • Peppol Four-Corner Model: Iceland runs a “delivery-based Peppol regime with no clearance” [2]. This model was established early, with Reglugerð 505/2013 in 2013 [21].
  • Tax Authority Role: VAT control is performed “post-audit by Skatturinn through a periodic return — there is no SAF-T, no transaction-level e-reporting and no clearance/CTC” [2]. There is “no monitoring mechanism for eInvoicing” [2].
  • Rationale: The B2G e-invoicing implementation aims for “efficiency, public-finance modernisation, [and] EEA alignment” with Directive 2014/55/EU [1]. By 2022, approximately “92% of B2G invoices received were already electronic XML” [2], demonstrating a high-adoption delivery-based ecosystem, rather than a fraud-driven clearance system.
  1. Scope of the Mandate: B2G Mandatory, B2B/B2C Voluntary

E-invoicing in Iceland is mandatory for B2G transactions on the receiving side, but remains voluntary for B2B and B2C transactions.

  • B2G Mandate (Receive-Side): Public bodies have been mandated to accept EN 16931 / TS 236 structured e-invoices since 1 January 2020 (state institutions from 18 April 2019) [2][19]. This is a “receive-side obligation” for public contracting authorities [2], but practically it becomes “de facto mandatory” for suppliers because “public bodies reject paper” and “non-compliant invoices are simply not paid” [2].
  • B2B/B2C Voluntary: “B2B/B2C: voluntary; not mandated” [2]. There is no domestic, cross-border, or export e-invoicing mandate for these transactions [2]. However, “B2B e-invoicing is voluntary and widely adopted by commercial agreement” due to support from Icelandic software and access points [31].
  • Transactions in Scope: For B2G, “public contracting authorities must receive and process EN 16931 / TS 236-compliant e-invoices for public procurement” [2]. For B2B and B2C, “e-invoicing is voluntary” [31].
  • Taxable Persons: Public contracting authorities are bound by the B2G acceptance obligation. For VAT, “every person carrying on a taxable business must register for VSK where turnover exceeds the threshold and file the bi-monthly return” [8]. The VAT registration threshold is ISK 2,000,000 [8]. There is “no e-invoicing obligation on ordinary businesses” [2].
  1. E-Invoice Formats and Standards

Iceland has a specific national standard for its mandatory B2G e-invoicing, built upon European norms.

  • Mandatory B2G Format: E-invoices for B2G transactions “must comply with EN 16931 and the Icelandic national CIUS ÍST TS 236, exchanged as Peppol BIS Billing 3.0 (UBL 2.1 syntax; UN/CEFACT CII also EN 16931-aligned)” [14][2]. PDF is “not accepted for B2G” [2].
  • National CIUS: ÍST TS 236:2021, titled “Rafrænt reikningaferli – Innleiðing á PEPPOL BIS Billing 3.0 og EN 16931,” is maintained by Staðlaráð Íslands (Icelandic Standards) [14]. It’s a “constrained implementation of Peppol BIS Billing 3.0 / EN 16931” [2].
  • Obsolete Standard: A key pitfall is “Standard confusion — the live standard is TS 236, not the obsolete ‘TS-136′” [14][2]. The “TS-136” standard (~2012) is “obsolete and should not be targeted by current systems” [2].
  • B2B Formats: For B2B, there is “no mandated format (PDF valid with consent)” [2]. Structured (TS 236 / Peppol / UBL) and unstructured (PDF, e-mail) formats are valid if the recipient consents and authenticity is ensured [31][35].
  1. Relationship with EU Directives and ViDA

Iceland’s status outside the EU VAT area significantly shapes its compliance obligations.

  • ViDA Exemption: Iceland is not bound by ViDA (VAT in the Digital Age). The “EEA Agreement excludes taxation, so ViDA (Council Directive (EU) 2025/516) does not apply” [5][6]. This means Iceland is “outside the EU VAT digital-reporting framework” [5].
  • Directive 2014/55/EU Applicability: While taxation is excluded, “Directive 2014/55/EU (procurement) does apply” because “public procurement is an internal-market matter” [4][1]. This is the basis for Iceland’s Peppol-based B2G framework.
  • No EC Sales List/Intra-Community Reporting: As Iceland is “outside the EU VAT area, so there is no EC Sales List / recapitulative statement” [2]. Cross-border goods flows are handled as imports/exports through customs [2].
  • Strategic Choice for Future B2B: Any move to B2B digital reporting in Iceland “would be an autonomous policy choice,” not an EEA mandate [5]. While its B2G format is technically convergent with EN 16931 (which ViDA would use), Iceland has “no digital-reporting (DRR) obligation” [14][2].
  1. VAT Reporting and Penalties

VAT administration is handled post-audit through periodic returns, with specific penalties for non-compliance.

  • Periodic VAT Returns: The VAT return (virðisaukaskattsskýrsla) is a “periodic summary return filed electronically to Skatturinn” [8]. The standard period is bi-monthly (six periods per year), with returns and payments due “one month and five days after the end of the period” [8].
  • No Pre-Filled Returns or Transaction-Level Reporting: “Iceland does not offer a pre-filled VAT return” [8]. There is “no SAF-T, no transaction-level e-reporting” [2]. All fields are self-prepared by the taxpayer [2].
  • No E-Invoicing Specific Penalties: There are “no e-invoicing-specific penalty” [8]. For B2G, “non-compliant invoices are simply not paid” [2]. For B2B, e-invoicing is voluntary.
  • VAT Penalties: Penalties are primarily for VAT compliance:
  • Late payment: “1% per day up to 10%, plus interest” [8].
  • Non-filing: A fixed surcharge of “ISK 5,000 where the tax is estimated for non-filing” [8].
  • Commercial Exposure: The “loss of input-VAT deduction for inadequately documented purchases is the practical commercial exposure” [22].
  1. Archiving and Retention Requirements

Taxpayers are responsible for their own record-keeping, with specific legal requirements.

  • No Central Archiving: There is “no central platform archiving of invoices” [2]. Taxpayers “retain their own books, records and invoices” [24].
  • Retention Period: Books, records, and supporting documents (including invoices) must be preserved for 7 years from the end of the fiscal year [24]. Annual financial statements must be kept for 25 years [24].
  • Storage Location: Records must “by default be preserved in Iceland.” Storage abroad is permitted for “a limited period” (capped at six months) [24]. Electronic accessibility for authorities must be maintained [24].
  • Integrity and Authenticity: “Authenticity of origin, integrity of content and legibility must be ensured throughout the retention period” through business controls, secure EDI, or electronic signatures/seals [21][35].
  1. Impact on SMEs and Startups

Iceland’s e-invoicing approach aims to minimize the burden on smaller businesses, particularly in B2B.

  • Low Onboarding Burden: There is “no e-invoicing onboarding burden for SMEs, because B2B e-invoicing is voluntary” [2].
  • Free/Low-Cost Tools: For B2G, the Fjársýsla ríkisins (FJS) provides the “Skuffan” supplier portal for manual submission of compliant TS 236 invoices [29]. Many access-point providers offer “free service up to a volume threshold” [2].
  • Simplified VAT Regimes: The VAT registration threshold is ISK 2,000,000. Businesses with turnover below ISK 4,000,000 may “file annually rather than bi-monthly” [8].
  • Low Compliance Costs: The “net burden is light: no e-invoicing mandate cost, a high-adoption ecosystem, and simplified annual VAT filing for the smallest businesses” [2]. There is no “clearance-integration cost” [31].

Key Takeaways and Risks

  • Iceland is a mature Peppol B2G market with no B2B mandate or clearance. Its e-invoicing landscape is stable and post-audit based.
  • Critical Action for Suppliers to Public Sector: Ensure systems generate valid ÍST TS 236 / Peppol BIS Billing 3.0 e-invoices. Do not target the obsolete “TS-136” standard, and PDFs are not accepted for B2G [14][2].
  • VAT Compliance: Timely filing of bi-monthly electronic VAT returns is crucial to avoid penalties (1% daily up to 10% for late payment) [8].
  • ViDA is not applicable to Iceland. Any future move towards B2B digital reporting would be an independent policy decision, not driven by EU mandates. Businesses should monitor developments but are not compelled to implement ViDA-related DRR [5].
  • Archiving Rules: Adhere to the 7-year retention period for records (25 years for annual accounts) and the default in-Iceland storage requirement [24].
  • FJS is the Peppol Authority and also manages central government invoice intake, offering the “Skuffan” portal for smaller suppliers [29][11].

 


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Extended summary

One-line orientation: Iceland is not a Continuous Transaction Controls (CTC) or clearance country. It has no mandatory domestic B2B or B2G e-invoicing clearance regime and no mandatory continuous transaction reporting (CTR) system in force. Electronic invoicing is used voluntarily and is supported in public procurement, but Iceland has not enacted a nationwide mandatory e-invoicing or digital-reporting mandate. As Iceland is not a member of the European Union, it is not directly subject to the EU ViDA timetable, although future developments may be influenced by the EEA framework and domestic policy decisions. [1][2][4]

Chapter 0 — Executive Summary (At-a-Glance)

MODEL NOTE — Iceland runs a delivery-based Peppol regime with no clearance. B2G e-invoice acceptance is mandatory and near-universal, but there is no tax-authority validation of invoices and no mandatory B2B e-invoicing. VAT is administered post-audit by Skatturinn through a periodic return — there is no SAF-T, no transaction-level e-reporting and no clearance/CTC.

Status

  • B2G: live and mandatory — public bodies must accept only EN 16931 / TS 236 structured e-invoices (from 1 January 2020; state institutions from 18 April 2019) [2][19]. B2B/B2C: voluntary; not mandated [2][31]. No transaction-level e-reporting [2].

Model

  • Delivery-based (Peppol four-corner) — not clearance/CTC. The EU country sheet labels the model “Delivery-based (Peppol)” and confirms “no monitoring mechanism for eInvoicing exists in Iceland”; the tax authority is not in the transaction path [2][32].

Mandatory format(s)

  • B2G: Peppol BIS Billing 3.0 / EN 16931, in the national CIUS ÍST TS 236 (UBL 2.1 syntax; CII also accepted). PDF is not accepted for B2G. B2B: no mandated format (PDF valid with consent) [14][2].

Key dates (acceptance vs issuance)

  • B2G receive-side obligation on public bodies from 18 April 2019 (state) / 18 April 2020 (municipalities), with TS 236-only acceptance from 1 January 2020 — de facto mandatory for suppliers. Statutory basis: Reglugerð 44/2019 under Art. 122 of Act 120/2016 [19][17].

Taxpayers in scope

  • Public contracting authorities must receive/process compliant e-invoices; suppliers to the State must invoice electronically in practice. All VAT-registered persons (VSK) file the bi-monthly VAT return. No B2B population is compelled to e-invoice [2][8].

Central platform / operator

  • Fjársýsla ríkisins (Financial Management Authority, FJS) is the State’s e-invoice recipient/processor and Iceland’s Peppol Authority since 2020; Skatturinn administers VAT. Delivery is via commercial Peppol access points and the FJS “Skuffan” supplier portal [11][29].

Penalty exposure

  • VAT: late-payment penalty 1% per day up to 10%, plus interest; a fixed ISK 5,000 surcharge where the tax is estimated for non-filing (VAT Act nr. 50/1988). No e-invoicing-specific penalty (B2G non-compliant invoices are simply not paid; B2B voluntary) [8][33].

ViDA alignment

  • N/A — not bound. Iceland is EEA/EFTA; the EEA Agreement excludes taxation, so ViDA (Council Directive (EU) 2025/516) does not apply. Directive 2014/55/EU (procurement) does apply — hence B2G Peppol. Advanced on Peppol B2G, outside the EU VAT digital-reporting framework [5][6].

Top 3 open risks / uncertainties

  • (1) Standard confusion — the live standard is TS 236, not the obsolete “TS-136”; ensure systems target the correct CIUS [14][2].
  • (2) Supplier obligation framing — statutorily a receive-side duty; de facto mandatory because public bodies reject paper [2].
  • (3) No ViDA compulsion — Iceland is under no EEA duty to adopt ViDA DRR, so cross-border digital-reporting alignment is a strategic choice, not a mandate [5].

Information cut-off date

  • 6 July 2026. All cited URLs were checked during research on this date [41].

 

 

Chapter 1 — Introduction & Country Context

1.1 Tax digitalisation journey

Iceland was an early Nordic adopter of e-invoicing to the State. Public-sector e-invoicing developed from the early 2010s (the four-corner model was established by Reglugerð 505/2013), the domestic standard evolved through the NES/CEN-BII generations to the current ÍST TS 236, and B2G acceptance became mandatory as the EU e-invoicing Directive was transposed via Reglugerð 44/2019 [21][14][19]. VAT (virðisaukaskattur, VSK) is administered by Skatturinn on a periodic-return, post-audit basis, with mandatory electronic filing of the return [8].

1.2 Rationale (efficiency, public-finance modernisation, EEA alignment)

Iceland’s B2G e-invoicing implements the EU/EEA single-market objective of interoperable public-sector invoicing under Directive 2014/55/EU, and reflects a domestic push by the Financial Management Authority (FJS) to automate central-government invoice intake [1][11]. By 2022, around 92% of B2G invoices received were already electronic XML — a high-adoption, delivery-based ecosystem rather than a fraud-driven clearance system [2].

1.3 Positioning — advanced on Peppol B2G, outside EU VAT reporting

Iceland is advanced on Peppol-based B2G (near-universal adoption; FJS as national Peppol Authority) but sits outside the EU VAT digital-reporting framework: as an EEA/EFTA state it applies the internal-market e-invoicing Directive but not the EU VAT Directive or the ViDA package (Chapter 16) [29][5]. It has no domestic B2B clearance system and none is planned [30][32].

1.4 Supranational authorisation / derogation

The B2G obligation derives from Directive 2014/55/EU, incorporated into the EEA Agreement by EEA Joint Committee Decision No. 166/2015 and implemented domestically by Reglugerð 44/2019 [4][19]. No VAT-Directive derogation is relevant, because Iceland is outside the EU VAT area and has no domestic B2B e-invoicing mandate [5][8].

Chapter 2 — Regulatory Framework

2.1 Primary legislation

The procurement framework is the Public Procurement Act — Lög um opinber innkaup nr. 120/2016 (in force 29 October 2016), whose Article 122 (122. gr.) is the enabling provision for the e-invoicing regulation [17][18]. The substantive VAT law is Lög nr. 50/1988 um virðisaukaskatt (VAT Act) — standard rate 24% and reduced rate 11% (with a zero rate on exports and international transport); credit invoices (kreditreikningur) are governed by Articles 13 and 20 [22][8][23]. Bookkeeping and archiving are governed by Lög um bókhald nr. 145/1994 (Bookkeeping Act) and financial reporting by Lög um ársreikninga nr. 3/2006 [24][25].

2.2 Implementing regulations & standards

The operative B2G instrument is Reglugerð nr. 44/2019 um rafræna reikninga vegna opinberra samninga (signed 9 January 2019, by the Ministry of Finance and Economic Affairs), issued under Article 122 of Act 120/2016; it requires public buyers to receive and process e-invoices complying with EN 16931, implemented via the Icelandic technical specification TS 236, and transposes Directive 2014/55/EU [19][20]. Earlier regulations 505/2013 (four-corner model, invoice content/transmission/authenticity) and 252/2018 (public bodies’ Peppol receiving capability) preceded it [21][2]. The national standard ÍST TS 236 is published and maintained by Staðlaráð Íslands (Icelandic Standards) [14].

2.3 Guidance & administrative practice

Skatturinn publishes VAT guidance and operates the electronic VAT-return service; FJS acts as the State’s e-invoice recipient and Peppol Authority, authorising access points and running the “Skuffan” supplier portal [8][11][29]. There is no monitoring mechanism for e-invoicing and no clearance guidance, because there is no clearance system [2].

2.4 Supranational / international legal basis

The B2G obligation rests on Directive 2014/55/EU (EEA-relevant, incorporated via EEA JCD 166/2015) and the CEN standard EN 16931 [4][3]. The EU VAT Directive 2006/112/EC and the ViDA package (Council Directive (EU) 2025/516) are not part of the EEA acquis and do not bind Iceland — the EEA Agreement excludes taxation (Chapter 16) [5][6].

Chapter 3 — Scope of the Mandate

3.1 Transactions in scope

B2G: public contracting authorities must receive and process EN 16931 / TS 236-compliant e-invoices for public procurement; in practice suppliers to the State must invoice electronically (paper/PDF are not accepted) [2][19]. B2B and B2C: e-invoicing is voluntary — there is no domestic, cross-border or export e-invoicing mandate [2][31]. Cross-border: Iceland is outside the EU VAT area, so there is no EC Sales List / recapitulative statement; cross-border goods flows are handled as imports/exports through customs (also administered by Skatturinn) [2][8].

3.2 Special transactions

MODEL NOTE — No clearance means no structured-e-invoicing treatment of special transactions. Self-billing, corrections and special VAT scenarios are governed by the VAT Act and reflected in the periodic VAT return — not in any e-invoice clearance flow (see Chapters 11–12) [22][8].

3.3 Excluded / exempt transactions

VAT-exempt activities follow the VAT Act’s exemption provisions and are not brought into any e-invoicing mandate; the zero rate applies to exports and international transport [8][23]. Because B2B e-invoicing is voluntary, there is no e-invoicing exclusion list to maintain outside the B2G acceptance rule [2].

Chapter 4 — Taxable Persons in Scope

4.1 Established domestic entities

Public contracting authorities are the bodies bound by the B2G acceptance obligation, and their suppliers must invoice electronically in practice [2]. For VAT, every person carrying on a taxable business must register for VSK where turnover exceeds the threshold and file the bi-monthly return; the VAT-registration threshold is ISK 2,000,000 of taxable turnover over any 12-month period [8][33]. There is no e-invoicing obligation on ordinary businesses [2].

4.2 Non-established entities

Non-established persons making taxable supplies in Iceland register for VSK and file the return on the same periodic basis; there is no e-invoicing mandate for them either [8][33]. Foreign suppliers of certain electronic services to Icelandic consumers register under the simplified VOES-type regime administered by Skatturinn [8].

4.3 Voluntary participation

B2B e-invoicing is voluntary and widely adopted by commercial agreement; TS 236 / Peppol are supported by Icelandic ERP and accounting software, and access points offer low-cost or free service up to a volume threshold, so structured e-invoicing is common without any mandate [31][2].

4.4 Sector-specific rules

There are no sector-specific e-invoicing mandates. Early adopters at the sub-central level (e.g. the City of Reykjavík, which required electronic supplier invoices from 2015) accelerated adoption, but the obligation is general rather than sector-based [39][2].

Chapter 5 — Implementation Timeline

5.1 Legislative history & milestones

  • 2013 — Reglugerð 505/2013 establishes the four-corner e-invoice model (content, transmission, authenticity) [21].
  • 30 June 2015 — City of Reykjavík accepts only EN 16931 CIUS (TS 236) electronic supplier invoices [39][2].
  • 29 October 2016 — Public Procurement Act nr. 120/2016 enters into force [17].
  • 2018 — Reglugerð 252/2018 (public bodies’ Peppol receiving capability); TS 236:2018 first edition issued [2][14].
  • 9 January 2019 — Reglugerð 44/2019 signed, transposing Directive 2014/55/EU (via EEA JCD 166/2015) [19][4].

5.2 Voluntary / pilot phases

There has been no clearance pilot, because Iceland has no clearance system. Adoption grew through the FJS-led central-government programme (including the 2019 INV-18 project using CEF eInvoicing) and organic B2B uptake on Peppol [2].

5.3 Mandatory dates — acceptance vs issuance

Under Reglugerð 44/2019 the compliance deadlines were 18 April 2019 for state institutions and 18 April 2020 for municipalities and other public entities, with FJS requiring TS 236-only acceptance across central government from 1 January 2020 [19][2]. The statutory obligation is on public bodies to receive/process compliant e-invoices; there is no separate supplier-issuance statute, but the practical effect is that suppliers must invoice electronically [2].

5.4 Grace periods & transitional provisions

The staggered 2019/2020 deadlines were themselves the transition. TS 236 was updated from the 2018 edition to TS 236:2021 (published 4 November 2021, effective 15 November 2021), aligning to Peppol BIS Billing 3.0, with a validation tool provided from 2020 [14].

5.5 Pre-mandate technical milestones

Icelandic Standards published the TS 236 specification and a validation tool; FJS provided the “Skuffan” supplier portal and authorised Peppol access points; and Skatturinn’s electronic VAT-return service is mandatory for filing [14][29][8].

5.6 Known / anticipated developments

As of the cut-off date there are no new e-invoicing mandates and no B2B clearance planned; the latest advisory coverage reports no pending changes [30][32]. Iceland is not obliged to adopt ViDA (Chapter 16), so any move to B2B digital reporting would be an autonomous policy choice [5].

Chapter 6 — Operating Model (How It Really Works)

6.1 Model type & role of the authorities

MODEL NOTE — Delivery-based (Peppol four-corner) — no clearance. The tax authority does not pre-validate or authorise invoices, and there is no monitoring mechanism. Structured e-invoices are delivered over the Peppol network to public bodies; VAT control is exercised post-audit through periodic returns [2][32].

For B2G, the sender’s access point transmits the TS 236 invoice through the Peppol network to the receiver’s access point and into the public body’s finance system; Fjársýsla ríkisins (FJS) is the central-government recipient/processor and Iceland’s Peppol Authority, and smaller suppliers can use the FJS “Skuffan” portal to key in an invoice manually [29][11]. For B2B, exchange is bilateral (Peppol, EDI or e-mail/PDF), with no authority in the path [31].

6.2 Invoice lifecycle

Because there is no clearance, the lifecycle is create → send (Peppol/other) → receive → book/pay → (post-audit) report — not create → submit → clear → deliver. The supplier issues the invoice; the sending access point validates it against TS 236/Peppol rules and transmits it; the receiver’s access point delivers it to the buyer’s system; the buyer books and pays it; and VAT is reported in the periodic return [2][8]. There is no per-invoice tax-authority validation step [2].

6.3 Authentication & access methods

Peppol participants are identified by Peppol IDs and exchange over the certified access-point network; suppliers using the FJS portal or Skatturinn’s services authenticate through island.is electronic identity (kennitála / rafræn skilríki) [29][8]. Invoice authenticity/integrity for VAT purposes may be ensured by business controls, secure EDI, or an electronic signature/seal — no digital signature is mandated [31][35].

6.4 Offline / contingency mode

There is no clearance platform to be unavailable, so no offline-clearance procedure exists. Peppol delivery is store-and-forward; where a supplier has no software, the FJS “Skuffan” web portal provides a manual channel to submit a compliant invoice [29][2].

6.5 Buyer-side workflow

The public buyer receives the structured invoice into its finance system for automated/semi-automated processing and payment; a non-compliant (non-TS 236) invoice is simply not accepted [2]. A B2B buyer books the invoice and exercises input-VAT deduction where entitled, reporting it in the periodic return; there is no platform accept/reject step [8][31].

6.6 QR / verification code requirements

There is no national QR-code or verification-code requirement for invoices, because there is no clearance or fiscalisation system; the structured Peppol/TS 236 document is machine-readable in itself [2][14].

Chapter 7 — Acceptable E-Invoice Formats

7.1 Mandatory format(s)

For B2G, an e-invoice must comply with EN 16931 and the Icelandic national CIUS ÍST TS 236, exchanged as Peppol BIS Billing 3.0 (UBL 2.1 syntax; UN/CEFACT CII also EN 16931-aligned) [14][2]. PDF is not a valid B2G e-invoice. For B2B/B2C, there is no mandated format — structured (TS 236 / Peppol / UBL) and unstructured (PDF, e-mail) are all valid provided the recipient consents and authenticity/integrity are ensured [31][35].

7.2 Relationship to international standards

ÍST TS 236 — full title “Rafrænt reikningaferli – Innleiðing á PEPPOL BIS Billing 3.0 og EN 16931” — is a national CIUS (constrained implementation of Peppol BIS Billing 3.0 / EN 16931), built on UBL 2.1 with conditional rules that apply for domestic Icelandic transactions; it is published by Staðlaráð Íslands (committee ÍST/FUT) [14][2]. Iceland therefore has a national CIUS but no divergent national format [2].

7.3 Voluntary / legacy / hybrid formats — and “TS-136”

The current standard is TS 236 (editions 2018 and 2021). It succeeded older Icelandic formats: the NES / TS-135 generation (~2007, a Northern European Subset of UBL 2.0) and TS-136 (~2012, built on CEN BII, pre-EN 16931). “TS-136” is obsolete and should not be targeted by current systems; it is mentioned here only for lineage accuracy [2][14]. Hybrid EU formats (Factur-X/ZUGFeRD) are not used; Peppol BIS is the exchange standard [2].

7.4 Attachments

Attachments travel within the Peppol BIS / UBL structure (embedded or referenced per the specification); for B2B outside Peppol, attachment handling is a matter of bilateral agreement, since no platform governs it [28][31].

Chapter 8 — Technical & Functional Requirements

8.1 E-invoice specifications

For B2G, the mandatory content is the EN 16931 semantic core expressed in the TS 236 CIUS (UBL 2.1), including the parties, the invoice and due dates, line detail, and the VAT breakdown; VAT must be shown separately and invoices consecutively numbered per the VAT Act [2][22]. There is no platform validation of individual invoices; validation is performed by the sending access point against Peppol/TS 236 rules [2].

8.2 E-reporting specifications — VAT return

The VAT return (virðisaukaskattsskýrsla) is a periodic summary return filed electronically to Skatturinn through the service web / island.is; the standard period is bi-monthly (six periods per year) and the return and payment are due one month and five days after the end of the period (the 5th day of the second month following) [8][34]. Alternative periods are annual (turnover below ISK 4,000,000), six-monthly (agriculture) and monthly (on request/special cases) [8]. There is no SAF-T, no transaction-level e-reporting and no recapitulative statement (Iceland is outside the EU VAT area) [2][8].

8.3 Digital signature & integrity

There is no per-invoice signature mandate; VAT integrity/authenticity may be ensured by business controls, secure EDI, or an electronic signature/seal, at the taxpayer’s choice [31][35]. Electronic bookkeeping and electronic storage are expressly permitted under the Bookkeeping Act nr. 145/1994 and Reglugerð 505/2013, which require traceable, non-alterable entries [24][21].

8.4 Processing mode & performance

Invoice exchange is not processed in real time by any authority (post-audit) [2]. VAT reporting is periodic (bi-monthly), not near-real-time. No platform performance/SLA targets apply, because there is no clearance platform; Peppol delivery follows the network’s own service model [2][28].

Chapter 9 — Correction of Errors

9.1 Invoice corrections

Corrections use a credit invoice (kreditreikningur) under the VAT Act nr. 50/1988: a credit invoice must always be issued for returns and for corrections of an earlier invoice, with reference to the original invoice, and a post-invoice discount only reduces taxable turnover where a credit invoice showing the VAT amount is issued (Articles 13 and 20) [22][23]. In a Peppol/TS 236 exchange the credit note is transmitted like any other document; there is no resubmission to a clearance platform, because none exists [2].

9.2 E-reporting corrections

Corrections flow into the periodic VAT return for the relevant period; an incorrect return is corrected by filing an amended return through Skatturinn’s electronic service, subject to the VAT Act’s timing rules and the late-payment/estimation consequences (Chapter 14) [8][33]. There is no corrective e-invoice-report process, because there is no transaction-level reporting [2].

Chapter 10 — Transmission & Workflow

10.1 Central platform(s)

There is no central invoicing platform. For B2G intake, Fjársýsla ríkisins (FJS) receives and processes central-government invoices and operates the “Skuffan” supplier portal; for VAT, Skatturinn’s electronic service web (via island.is) is the filing channel [11][29][8]. Delivery of e-invoices is decentralised over the Peppol network [2].

10.2 Transmission channels

B2G: the Peppol four-corner network via certified access points, or the FJS “Skuffan” web portal for suppliers without software [29][2]. B2B: Peppol, EDI or e-mail/PDF by agreement [31]. VAT reporting: the electronic VAT return through Skatturinn / island.is [8].

10.3 Accredited service providers & the Peppol Authority

Iceland’s Peppol Authority is Fjársýsla ríkisins (FJS), designated in 2020, which authorises access points and sets service-provider requirements [29][26]. Certified Peppol access points serving Iceland include the Icelandic-domiciled Advania and Unimaze, alongside Wise, Sendill, InExchange, Pagero, Basware, Storecove and EDICOM; Icelandic accounting/ERP software (Wise, DK, Origo, and others) integrates Peppol/TS 236 [27][31][36].

10.4 Interoperability with B2G / Peppol / cross-border

Interoperability is achieved through Peppol and EN 16931 compliance; cross-border e-invoice exchange uses the same Peppol network [28][2]. There is no domestic cross-border e-invoice clearance and no intra-EU reporting, since Iceland is outside the EU VAT area [8].

10.5 Deadlines & timing

There is no invoice-transmission deadline to an authority (post-audit) [2]. The VAT return and payment are due one month and five days after the bi-monthly period ends; the annual financial statements are filed electronically to the Annual Accounts Register within eight months of year-end [8][25].

Chapter 11 — Self-Billing

Self-billing (the customer issuing the invoice in the supplier’s name by prior agreement) is a VAT-documentation arrangement under the general rules, not an e-invoicing or clearance feature, and Iceland operates no clearance platform to govern it [22][8]. Accordingly, on the available sources the classic self-billing sub-questions do not have platform-level answers: legality rests on agreement between the parties and the ordinary invoicing rules; there is no platform routing, no tax-authority authorisation step, no prescribed system “self-billing” flag beyond the ordinary invoice content, no special foreign-buyer restriction beyond the general rules, and buyer-side approval is governed by the agreed procedure [22][31]. Both parties still account for the VAT in their periodic returns [8]. Where a specific self-billing arrangement is contemplated it should be confirmed against the VAT Act and current Skatturinn guidance [22].

Chapter 12 — Cross-Border & Special Scenarios

12.1 Cross-border supplies (imports/exports)

Iceland is outside the EU VAT area, so there is no intra-Community-acquisition or EC Sales List regime; exports of goods and international transport are zero-rated, and imports are subject to import VAT collected at the border by Skatturinn (also the customs authority) [8][2]. None of this involves an e-invoice clearance flow [2].

12.2 Reverse charge on imported services

Recipients of certain services from abroad self-assess Icelandic VAT (reverse charge) and account for it in the periodic VAT return, under the VAT Act; this is a VAT-accounting mechanism, not an e-invoicing rule [8][22].

12.3 Zero-rated & exempt supplies

The zero rate applies to exports and international transport; exempt activities (with no input-VAT deduction) follow the VAT Act’s exemption provisions [8][23]. There are no e-invoice “exemption code” fields to populate beyond the standard EN 16931 / TS 236 VAT categorisation, because there is no clearance schema to feed [2][14].

12.4 Triangulation & chain transactions

EU intra-Community triangulation and chain-transaction simplifications do not apply to Iceland, which is outside the EU VAT area; multi-party cross-border flows are handled through the ordinary import/export and reverse-charge rules [8][2].

12.5 Local nuances

VAT grouping, fiscal representation for certain non-established persons, and the simplified regime for foreign suppliers of electronic services are VAT-accounting features administered by Skatturinn and reflected in the returns, not in an e-invoicing mandate [8][33].

Chapter 13 — Archiving & Retention

13.1 Central archiving by a platform

There is no central platform archiving of invoices, because there is no clearance system; taxpayers retain their own books, records and invoices [24][2]. FJS holds the central-government invoices it processes, and Skatturinn holds the submitted VAT returns and annual accounts [11][8].

13.2 Mandatory archiving format

The Bookkeeping Act does not mandate a single archival format; records may be retained electronically (electronic form, microfilm or comparable media) provided they remain accessible and printable, with paper and electronic records treated equally under Reglugerð 505/2013 [24][21].

13.3 Retention period

Books, records and supporting documents (including invoices) must be preserved for 7 years from the end of the relevant fiscal year under Article 20 of the Bookkeeping Act nr. 145/1994; annual financial statements must be kept for 25 years [24]. These are the general accounting-law retention rules that also govern VAT documents [8].

13.4 Storage location

Records must by default be preserved in Iceland; storage abroad is permitted only for a limited period (the Bookkeeping Act caps foreign storage at six months, with the authorities retaining the right to require return), a stricter rule than some vendor summaries suggest [24]. Electronic accessibility for the authorities must be maintained [24][35].

13.5 Integrity, authenticity, readability

Authenticity of origin, integrity of content and legibility must be ensured throughout the retention period, by business controls, secure EDI, or an electronic signature/seal; Reglugerð 505/2013 requires traceable, non-alterable entries with corrections only via a new invoice or credit note [21][35].

13.6 Audit accessibility

Audit access is on-demand from the taxpayer (production of retained records), since there is no real-time platform archive to query; Skatturinn conducts post-audit VAT control [2][8].

Chapter 14 — Penalties & Enforcement

14.1 Graduated enforcement

VAT enforcement is post-audit and centred on the periodic return: late payment attracts a daily penalty and interest, and non-filing leads to an estimated assessment with a surcharge [8][33]. B2G e-invoicing is enforced commercially — a non-compliant invoice is simply not accepted or paid — with no formal monitoring mechanism [2].

14.2 Penalties by category

Under the VAT Act nr. 50/1988: a late-payment penalty of 1% per day, up to a maximum of 10%, applies to VAT paid late; penalty interest (at the Central Bank of Iceland’s rate) accrues once the VAT remains unpaid one month after the due date; and where the tax authority estimates the VAT because the taxpayer failed to file, a fixed surcharge (álag, reported at ISK 5,000) applies [8][33]. There is no e-invoicing-specific penalty: B2B e-invoicing is voluntary, and B2G is enforced through procurement/payment practice rather than a fine [2][29].

14.3 Amounts & escalation

The daily 1% late-payment penalty caps at 10% of the amount due, with Central-Bank penalty interest running thereafter; serious or repeated non-compliance is pursued under the general tax-enforcement and collection rules administered by Skatturinn [8][33]. Loss of input-VAT deduction for inadequately documented purchases is the practical commercial exposure [22].

14.4 References & links

The governing provisions are in the VAT Act nr. 50/1988 (administered by Skatturinn), with the procurement obligation in Act nr. 120/2016 and Reglugerð 44/2019; the Bookkeeping Act nr. 145/1994 governs record-keeping penalties [22][19][24]. PwC provides current interpretation of the VAT penalty regime [33].

Chapter 15 — Pre-Filled VAT Returns

15.1 Available today?

MODEL NOTE — No. Iceland does not offer a pre-filled VAT return. The VAT return is a self-prepared periodic summary return filed electronically to Skatturinn; there is no transaction-level data feed to populate it [8][2].

15.2 Fields pre-filled vs input required

All fields are input by the taxpayer from its own books; because there is no clearance or transaction-level e-reporting, the tax authority holds no per-invoice data to pre-populate the return [2][8].

15.3 Announced plans & timeline

No dated project for a pre-filled VAT return has been identified, and no transaction-level reporting is planned [30][32].

15.4 Dependency on e-invoicing/e-reporting data

Any future pre-population would require transaction-level data that Iceland does not currently collect; the Peppol B2G flow is a delivery mechanism, not a reporting feed [2].

15.5 Alignment with ViDA pre-filled provisions

ViDA does not bind Iceland (Chapter 16), and it does not itself mandate pre-filled returns; Iceland is under no obligation to build the DRR data that could support pre-population [5][6].

Chapter 16 — ViDA / International Digital Reporting Readiness

16.1 Country position

MODEL NOTE — N/A — Iceland is not bound by ViDA. The EEA Agreement excludes taxation, so the EU VAT Directive (2006/112/EC) and the VAT in the Digital Age package (Council Directive (EU) 2025/516, adopted 11 March 2025) are not part of the EEA acquis and do not apply to Iceland [5][6].

By contrast, Directive 2014/55/EU (e-invoicing in public procurement) is EEA-relevant — public procurement is an internal-market matter — which is why Iceland has a Peppol-based B2G framework [4][1]. Iceland is therefore advanced on Peppol B2G but sits outside the EU VAT digital-reporting framework [29].

16.2 Alignment of national format & model

Iceland’s national CIUS TS 236 is already Peppol BIS Billing 3.0 / EN 16931-aligned, so its B2G format is technically convergent with the standard ViDA would use; however, Iceland has no digital-reporting (DRR) obligation and no domestic B2B mandate, so the reporting model does not mirror ViDA’s per-transaction requirements [14][2].

16.3 Cross-border digital reporting

ViDA’s Digital Reporting Requirements (mandatory structured e-invoicing and near-real-time reporting for intra-EU B2B from 1 July 2030, replacing recapitulative statements) do not extend to Iceland, which has no EC Sales List obligation to begin with [5][8]. EU–EEA VAT cooperation runs through separate administrative-cooperation arrangements rather than the VAT Directive [5].

16.4 Business implications

Icelandic-established businesses trading with the EU are not required to implement ViDA DRR, but those with EU establishments or EU-side obligations will be caught by ViDA in those Member States; using Peppol BIS / EN 16931 (already the Icelandic B2G standard) is useful groundwork for any voluntary or EU-driven alignment [2][5]. Iceland could adopt Peppol-based B2B reporting autonomously in future, but is under no EEA compulsion to do so [29][5].

Chapter 17 — Impact on SMEs and Startups

17.1 Onboarding

There is no e-invoicing onboarding burden for SMEs, because B2B e-invoicing is voluntary; a small supplier to the State needs only a way to send a TS 236 invoice — either through an access point or the free FJS “Skuffan” portal [2][29].

17.2 Free / low-cost tools & education

The FJS “Skuffan” portal lets suppliers without an accounting system send TS 236 invoices manually, and several access-point providers offer free service up to a volume threshold; Icelandic accounting/ERP packages (Wise, DK, Origo and others, plus bank channels such as Íslandsbanki) include Peppol/e-invoicing integration [2][31].

17.3 Simplified regimes & thresholds

The VAT-registration threshold is ISK 2,000,000 of taxable turnover over any 12-month period (raised from ISK 1,000,000 in 2017), keeping micro-enterprises outside VAT; businesses with turnover below ISK 4,000,000 may file annually rather than bi-monthly [33][8].

17.4 Subsidies, tax credits, grants

No dedicated e-invoicing subsidy exists, and none is needed given the voluntary, low-cost position; the free FJS portal and low-cost access points are the effective support [2][29].

17.5 Compliance costs

For SMEs the principal ongoing cost is the periodic VAT return, not e-invoicing software; there is no clearance-integration cost, and structured e-invoicing is already embedded in mainstream Icelandic software [8][31].

17.6 Cash-flow & operational benefits

Voluntary Peppol/TS 236 e-invoicing delivers automation and faster processing without a mandate, and B2G acceptance guarantees suppliers an electronic route to invoice public bodies (which pay electronically) [2][31].

17.7 Net administrative burden vs simplification

The net burden is light: no e-invoicing mandate cost, a high-adoption ecosystem, and simplified annual VAT filing for the smallest businesses [2][8].

17.8 Market & competitive impact

Because e-invoicing is voluntary in B2B, there is no market-exclusion effect; the practical driver is public-sector demand for TS 236 and customer/ERP demand for Peppol [2][31].

17.9 Official assessments of SME readiness

Iceland’s high B2G adoption (around 92% of B2G invoices electronic by 2022) indicates strong readiness; there is no separate SME-readiness assessment for a B2B mandate, since none exists [2].

Chapter 18 — Practical Implementation Considerations

18.1 ERP / finance-system impacts

Icelandic accounting/ERP systems (Wise, DK, Origo, and others) and global ERPs (SAP, Oracle, Microsoft Dynamics 365) connect to Iceland through certified Peppol access points rather than any clearance system; the main system task is generating a valid TS 236 / Peppol BIS invoice for B2G and filing the electronic VAT return [31][2]. There is no clearance integration to build [2].

18.2 Master-data prerequisites

Key master data are the Peppol participant identifiers (typically based on the kennitála/organisation number) for sender and receiver, correct VAT categorisation for the EN 16931/TS 236 fields, and valid counterparty details; there is no clearance credential to provision [2][14].

18.3 Common pitfalls

Documented pitfalls include targeting the wrong standard (the obsolete “TS-136” instead of the current TS 236), sending a PDF where a structured B2G invoice is required, and missing the VAT-return deadline (period-end + one month five days) [14][8]. On the invoicing side, the usual pitfall is sending electronic invoices in B2B without documented consent or an assured audit trail [31].

18.4 Vendor / service-provider landscape

The Peppol Authority is FJS; certified access points serving Iceland include the Icelandic-domiciled Advania and Unimaze, plus Wise, Sendill, InExchange, Pagero, Basware, Storecove and EDICOM [26][27][36]. There is no clearance-provider accreditation, and no state Peppol gateway beyond the FJS “Skuffan” supplier portal [2][29].

18.5 Governance & internal control

Internal controls should ensure valid TS 236/Peppol output for public-sector customers, a documented audit trail linking invoices to supplies for VAT integrity, accurate and timely bi-monthly VAT returns, and correct 7-year (25-year for annual accounts) retention with the domestic-storage rule observed [2][8][24].

Chapter 19 — Summary & Key Takeaways

19.1 Scope

Mandatory B2G e-invoice acceptance (EN 16931 / TS 236) with de-facto supplier issuance; voluntary B2B/B2C; periodic VAT returns for VSK-registered persons [2][8].

19.2 Format

B2G: Peppol BIS Billing 3.0 / EN 16931 in the national CIUS ÍST TS 236 (UBL 2.1); B2B: no mandated format (PDF valid with consent). “TS-136” is obsolete [14][2].

19.3 Timeline

Four-corner model 2013; Reykjavík 2015; Act 120/2016; Reglugerð 44/2019 (state 18 Apr 2019, municipalities 18 Apr 2020; TS 236-only from 1 Jan 2020); TS 236:2021 [21][39][19][14].

19.4 How it works

Delivery-based Peppol four-corner — no clearance; FJS receives central-government invoices and is the Peppol Authority; Skatturinn administers VAT post-audit [2][29][8].

19.5 Key obligations

Send/receive TS 236 e-invoices for public-sector trade; file the bi-monthly VAT return; issue credit invoices for corrections; retain records 7 years (annual accounts 25) [2][8][22][24].

19.6 Main risks

Targeting the obsolete “TS-136”; the receive-side vs supplier framing; and (strategically) no ViDA compulsion, so cross-border alignment is a choice [14][2][5].

19.7 SME implications

No e-invoicing mandate cost; free FJS “Skuffan” portal and low-cost access points; ISK 2,000,000 VAT threshold; annual filing below ISK 4,000,000 [2][33][8].

19.8 ViDA / international readiness

N/A — not bound (EEA excludes taxation); advanced on Peppol B2G; outside the EU VAT digital-reporting framework [5][29].

19.9 Critical dates & next steps (actionable)

  • Now (live): ensure public-sector output is valid TS 236 / Peppol BIS (not the obsolete “TS-136”); file the bi-monthly VAT return by period-end + one month five days [14][8].
  • Standing controls: issue credit invoices for corrections; retain records 7 years (annual accounts 25) with the in-Iceland storage default; maintain e-invoice audit trails [22][24].
  • Strategic: treat Peppol/EN 16931 adoption as future-proofing for any voluntary or EU-driven B2B reporting — Iceland is under no ViDA compulsion, so monitor rather than pre-build a mandate [5][29].

 

 

Chapter 20 — Official References & Sources

All URLs were checked during research on the information cut-off date, 6 July 2026. Sources flagged [>12 months] are older than 12 months and used for historical/background context (the governing statutes remain current despite their dates). A key correction is disclosed throughout: the current national standard is ÍST TS 236, not “TS-136” (an obsolete ~2012 predecessor). Numbering [1]–[40] is stable across the booklet; [41] is the verification note.

20.1 EU / EEA institutions & Directives

[1] eInvoicing in Iceland (country page; B2G model; Reg 44/2019 & 505/2013). European Commission — Digital Building Blocks, updated 13 Aug 2025. https://ec.europa.eu/digital-building-blocks/sites/spaces/DIGITAL/pages/467108903/eInvoicing+in+Iceland

[2] 2025 Iceland eInvoicing Country Sheet (delivery-based Peppol; TS 236 CIUS; no monitoring; no B2B mandate). European Commission — Digital Building Blocks, 13 Aug 2025. https://ec.europa.eu/digital-building-blocks/sites/spaces/einvoicingCFS/pages/881983581/2025+Iceland+2025+eInvoicing+Country+Sheet

[3] Directive 2014/55/EU on electronic invoicing in public procurement. EUR-Lex, 16 Apr 2014. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0055  [>12 months]

[4] Directive 2014/55/EU — EEA incorporation (EEA JCD 166/2015; status: implemented). EEA transposition database (stjórnarráðið), accessed 2026. https://gagnagrunnur.ees.is/32014l0055

[5] Q&A about the EEA Agreement (EEA excludes direct and indirect taxation). EFTA, accessed 2026. https://www.efta.int/eea-relations-eu/qa-about-eea-agreement

[6] VAT in the Digital Age (ViDA) — EU scope. European Commission — Taxation and Customs Union, accessed 2026. https://taxation-customs.ec.europa.eu/taxation/vat/vat-digital-age-vida_en

[7] Council Directive (EU) 2025/516 — VAT in the Digital Age (ViDA). EUR-Lex, 11 Mar 2025. https://eur-lex.europa.eu/eli/dir/2025/516/oj/eng

20.2 Icelandic government & tax authority

[8] Value Added Tax (VSK) — rates, periods, filing, threshold. Skatturinn (Iceland Revenue and Customs), accessed 2026. https://www.skatturinn.is/english/companies/value-added-tax/

[9] Skattskylda og skattprósentur (VAT rates 24% / 11%). Skatturinn, accessed 2026. https://www.skatturinn.is/atvinnurekstur/virdisaukaskattur/skattskylda-og-skattprosentur/

[10] Key rates and amounts 2026. Skatturinn, 2026. https://www.skatturinn.is/english/individuals/key-rates-and-amounts/2026/

[11] The Financial Management Authority (Fjársýsla ríkisins / FJS) — role. island.is (Stafrænt Ísland), accessed 2026. https://island.is/en/o/the-financial-management-authority

[12] The Financial Management Authority — collection and invoicing. island.is, accessed 2026. https://island.is/en/o/the-financial-management-authority/collection-and-invoicing

[13] Ministry of Finance and Economic Affairs (Fjármála- og efnahagsráðuneytið). Stjórnarráðið (Government of Iceland), accessed 2026. https://www.stjornarradid.is/raduneyti/fjarmala-og-efnahagsraduneytid/

[14] ÍST TS 236:2021 — Rafrænt reikningaferli (Peppol BIS Billing 3.0 & EN 16931). Staðlaráð Íslands (Icelandic Standards), 4 Nov 2021. https://www.stadlar.is/stadlabudin/vara/?ProductName=IST-TS-236-2021  [>12 months]

[15] Taxes on goods and services (overview). island.is, accessed 2026. https://island.is/en/taxes-on-goods-and-services

[16] Ríkiskaup — Central Public Procurement (State Trading Centre). Ríkiskaup, accessed 2026. https://www.rikiskaup.is/

20.3 Legislation & regulations

[17] Lög um opinber innkaup nr. 120/2016 (Public Procurement Act; Art. 122). Alþingi (Icelandic Parliament), consolidated. https://www.althingi.is/lagas/nuna/2016120.html

[18] Act on Public Procurement No. 120/2016 (English). Ministry of Finance and Economic Affairs, 2016. https://www.stjornarradid.is/media/fjarmalaraduneyti-media/media/frettatengt2016/act-on-public-procurment-no.-120-2016.pdf  [>12 months]

[19] Reglugerð nr. 44/2019 um rafræna reikninga vegna opinberra samninga (official gazette). Stjórnartíðindi (Icelandic Official Gazette), 9 Jan 2019. https://adverts.stjornartidindi.is/B_nr_44_2019.pdf  [>12 months]

[20] Reglugerð nr. 44/2019 (record). island.is / Reglugerðasafn, 2019. https://island.is/reglugerdir/nr/0044-2019  [>12 months]

[21] Reglugerð nr. 505/2013 (four-corner e-invoice model). island.is / Reglugerðasafn, 2013. https://island.is/reglugerdir/nr/0505-2013  [>12 months]

[22] Lög nr. 50/1988 um virðisaukaskatt (VAT Act, consolidated). Alþingi, consolidated. https://www.althingi.is/lagas/nuna/1988050.html

[23] The Value Added Tax Act with subsequent amendments (English). Government of Iceland (stjórnarráðið), consolidated. https://www.government.is/library/Files/The_Value_Added_Tax_Act_with_subsequent_amendments.pdf  [>12 months]

[24] Lög um bókhald nr. 145/1994 (Bookkeeping Act; Art. 20 retention). Alþingi, consolidated (Apr 2026). https://www.althingi.is/lagas/nuna/1994145.html

[25] Lög um ársreikninga nr. 3/2006 (Financial Statements Act). Alþingi, consolidated. https://www.althingi.is/lagas/nuna/2006003.html

20.4 Peppol & technical specifications

[26] Iceland — Peppol country profile (Peppol Authority: FJS). OpenPeppol, updated 1 Feb 2022. https://peppol.org/learn-more/country-profiles/iceland/  [>12 months]

[27] Peppol certified service providers (directory). OpenPeppol, updated 2026. https://peppol.org/members/peppol-certified-service-providers/

[28] Peppol BIS Billing 3.0 specification. OpenPeppol (docs.peppol.eu), accessed 2026. https://docs.peppol.eu/poacc/billing/3.0/bis/

20.5 Advisor & technology publications

[29] Iceland’s role as Peppol Authority — advancing e-invoicing (FJS since 2020). VATupdate.com, 15 Aug 2025. https://www.vatupdate.com/2025/08/15/icelands-role-as-peppol-authority-advancing-e-invoicing-in-public-and-private-sectors/

[30] E-invoicing in Iceland — Peppol requirements, formats and compliance. VATupdate.com, 13 Mar 2026. https://www.vatupdate.com/2026/03/13/e-invoicing-in-iceland-peppol-requirements-formats-and-compliance-for-public-sector-suppliers/

[31] Iceland electronic invoicing & Peppol (B2G mandate; B2B voluntary; TS 236 CIUS). EDICOM, 12 Aug 2025. https://edicomgroup.com/blog/iceland-electronic-invoicing-peppol

[32] Iceland e-invoicing (Interoperability / Post-Audit; TS 236; archiving). ecosio, 26 Nov 2025. https://ecosio.com/en/compliance/iceland/e-invoicing/

[33] Iceland — Other taxes (VAT rates, threshold, penalties). PwC Worldwide Tax Summaries, reviewed 28 Jan 2026. https://taxsummaries.pwc.com/iceland/corporate/other-taxes

[34] Icelandic VAT returns (bi-monthly; deadlines). Avalara (VATlive), 23 Jun 2026. https://www.avalara.com/us/en/vatlive/country-guides/europe/iceland/icelandic-vat-returns.html

[35] Iceland e-invoicing compliance map (formats, archiving, integrity). Basware, accessed 2026. https://www.basware.com/en/compliance-map/iceland

[36] E-invoicing in Iceland (Icelandic Peppol access point). Unimaze, 28 Mar 2023. https://www.unimaze.com/e-invoicing-in-iceland/  [>12 months]

[37] E-invoicing in Iceland — complete guide. Marosa, accessed 2026. https://marosavat.com/vat-news/e-invoicing-iceland-complete-guide

[38] E-invoicing in Iceland. Storecove, accessed 2026. https://www.storecove.com/blog/en/einvoicing-iceland/

[39] Automated electronic invoices (Reykjavík — TS 236 requirement). City of Reykjavík, accessed 2026. https://reykjavik.is/en/automated-electronic-invoices

[40] Iceland — e-invoicing regulatory updates. Pagero / Thomson Reuters, accessed 2026. https://www.pagero.com/compliance/regulatory-updates/iceland



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