The NZ$33 Million Threshold: Which Suppliers Must E-Invoice in 2027

The NZ$33 million threshold in one sentence

A supplier is "large" — and therefore in scope for New Zealand's 2027 e-invoicing requirement — if the total revenue of the entity and its subsidiaries exceeded NZ$33 million in each of the two preceding accounting periods. The requirement itself, and what to do about it, is covered in our New Zealand eInvoicing 2027 guide for large suppliers; this article is only about how the test is calculated.

Three parts to the test

The definition looks simple but has three moving parts that each change the answer:

1. Total revenue of the entity and its subsidiaries — a group figure, not a single company.
2. Exceeded NZ$33 million — revenue must be above the line, not merely at it.
3. In each of the two preceding accounting periods — both prior periods, not one.

Miss any one of these and you can misclassify yourself.

"Entity and its subsidiaries" — assess the group

The revenue figure is measured across the entity and its subsidiaries together. A holding company with modest standalone revenue can still be a large supplier once its subsidiaries are consolidated. Conversely, one subsidiary in a larger group is assessed as part of that group, not in isolation.

If your organisation reports consolidated group accounts, that consolidated revenue line is the right starting point. If you operate several New Zealand entities, work out which of them form the relevant group before comparing to NZ$33 million.

"Each of the two preceding accounting periods" — both years

This is the part most often misread. Revenue must have exceeded NZ$33 million in each of the two preceding accounting periods. A worked example:

Here the supplier is not large, because one of the two periods fell below the line. Only if both periods exceed NZ$33 million does the supplier meet the test. Because businesses use different balance dates, apply this to your own two most recent completed accounting periods rather than a fixed calendar year.

What revenue, and which invoices

The associated requirement is scoped to domestic trade credit — invoices in New Zealand dollars for goods or services delivered in New Zealand in the normal course of business. That scope tells you which invoices the 2027 Peppol requirement touches; the NZ$33 million test tells you whether you, as a supplier, are caught at all. Confirm the current rules for your specific circumstances.

Are you in scope?

• [ ] Identify the correct entity and subsidiaries to consolidate.
• [ ] Pull total revenue for the two most recent completed accounting periods.
• [ ] Check whether each period exceeded NZ$33 million.
• [ ] If both did, treat yourself as a large supplier.
• [ ] If you are close in either period, prepare as if in scope.
• [ ] Confirm which of your flows are domestic trade credit.

How GoRoute helps

Whether or not you clear the NZ$33 million line, being able to send a compliant Peppol e-invoice is inexpensive insurance. GoRoute (POP000991) is a certified Peppol Access Point and SMP, and an ATO-accredited Australian Peppol Service Provider also pursuing New Zealand mutual accreditation with MBIE. We map your billing data to PINT A-NZ, validate it, and send it to New Zealand agencies and Australian buyers through one REST API. If you decide you are — or might be — a large supplier, book a demo and we will help you get connected.

Sources: New Zealand Government Procurement — eInvoicing; MBIE; Peppol / OpenPeppol.