A new draft law introducing the Mandatory E-Invoicing System in North Macedonia

The Government of North Macedonia has published a Draft Law on Electronic Invoicing, introducing a centralized electronic invoicing (e-invoicing) system which is to be administered by the Public Revenue Office. Under the proposed framework, the tax office will establish and manage a central e-invoicing platform through which electronic invoices will be issued, validated, received, accepted, rejected, corrected, cancelled, and stored. 

To be considered legally valid, an electronic invoice must:

• Be issued through the e-invoicing system
• Be signed using a qualified electronic signature
• Receive a unique invoice identification number and electronic timestamp following successful validation within the system

The obligation to issue and receive e-invoices will apply to a broad range of taxpayers, including:

• VAT-registered businesses
• Non-VAT registered entities carrying out business activities
• Individuals carrying out business activities, even if not registered for VAT purposes
• Public sector bodies and state-controlled entities
• Appointed fiscal representatives for VAT purposes
• Recipients of supplies from foreign entities where the cross-border reverse charge mechanism applies
• Other categories of taxpayers specified by the draft law

Certain transactions will remain outside the scope of the mandatory e-invoicing regime, i.e., the transactions for which a fiscal receipt has been issued, as well as the banking and financial supply - which is exempt from VAT.

Implementation Timeline

The proposed legislation envisages a phased implementation of the e-invoicing regime:

• 1 October 2026 - Voluntary registration and use of the e-invoicing system commence
• 1 April 2027 - Mandatory use of e-invoicing for VAT-registered taxpayers, including public sector entities
• 1 July 2027 - Mandatory use of e-invoicing for non-VAT registered entities engaged in business activities
• 1 October 2027 - Mandatory use of e-invoicing for budget users and other public institutions
• 1 January 2028 - Mandatory issuance and receipt of e-invoices for all entities conducting transactions

What Should Businesses Do?

Considering that the testing and implementation phase of the e-invoicing system commenced in January 2026, taxpayers are advised to review their existing systems and processes and, where necessary, make appropriate updates to ensure alignment with both the instructions issued by the tax authorities at the outset of the testing phase and the requirements envisaged under the draft law.

Given the phased implementation approach, proactive planning and the timely execution of any necessary adjustments will help mitigate potential compliance risks and facilitate a seamless transition once the legislation is enacted and the technical specifications of the e-invoicing platform are finalized.