E-Invoicing in North Macedonia: Voluntary from 1 October 2026, Mandatory from April 2027

The Ministry of Finance has published a draft of a new Law on Electronic Invoicing, available for public consultation on the ENER portal since 21 August 2026. If adopted in this form, the Public Revenue Office's e-Faktura system opens for voluntary registration on 1 October 2026, while mandatory application is introduced in phases — from April 2027 to January 2028. The change is not merely technical: for covered entities, an invoice that has not passed through the PRO system will not be treated as issued in accordance with the law. Here is what practically changes for companies and what should be prepared in time.

What is e-Faktura and who is covered by the obligation?

An e-Faktura is an invoice in a structured electronic format that is issued, transmitted and received through the PRO's centralised system — via direct integration of business software (API) or through a client, web or mobile application. This is not a PDF sent by email: the system validates the invoice and assigns it a Unique Invoice Identifier (EIF) and an electronic timestamp, while the printed visual representation carries the same legal and evidentiary force as the electronic original, with validity verifiable through a QR code.

Unlike earlier announcements, the obligation no longer rests on amendments to the VAT Law but on a new, standalone statute. It covers nearly everyone making supplies: VAT-registered taxpayers, legal and natural persons carrying out an economic activity even if not VAT-registered, budget users and non-profit institutions, the National Bank, entities conducting enforced collection and tax representatives. Exceptions are provided for turnover subject to fiscal receipts, for public procurement in the field of defence and security, and for certain VAT-exempt transactions.

Which deadlines apply: a voluntary start and four mandatory phases

The transitional provisions of the draft law provide a precise calendar, which differs from the initially announced timelines:

Two points deserve attention. First, voluntary registration is a one-way door: from the day of registration the entity is obliged to issue all invoices exclusively through the system — there is no going back to paper. Second, the law enters into force on the eighth day after publication in the Official Gazette and applies from 1 October 2026, with secondary legislation detailing the procedures to follow within three months. As this is still a draft, the final deadlines depend on the parliamentary procedure — but the direction is clear, and preparation is worth starting while registration is still voluntary.

Does an invoice without PRO validation have legal effect?

For covered entities, as a basic rule it does not. The draft law sets three cumulative conditions for legal validity: the invoice must be issued through the system in a structured format, signed with a qualified electronic signature certificate, and validated by the system with an assigned EIF and timestamp. From the day mandatory application begins for each category, invoices not issued or received through the system are explicitly treated as not issued in accordance with the law.

That has three concrete consequences. First, the buyer risks losing the right to deduct input VAT on such an invoice, which directly raises the cost of the purchase. Second, the accountant cannot book it as a proper commercial record. Third, in a payment dispute the non-validated invoice is weaker evidence: the PRO system's record of issuance and receipt carries far more weight before a court or enforcement agent than a PDF the other side claims never to have received.

One nuance is worth remembering: the system's validation is not a confirmation of the material accuracy, lawfulness or tax treatment of the transaction. The system checks form and arithmetic, not substance — responsibility for what is invoiced remains with the issuer.

Acceptance, rejection and correction: the new dynamic between issuer and recipient

The draft law introduces a formal exchange that does not exist with paper invoices. An invoice is deemed issued and received at the moment it becomes available on the system and an electronic notification is sent — not when it is created. The recipient may accept or reject it no later than the 10th day of the month following the month of the transaction; if the recipient does not react within that period, the invoice is deemed accepted and becomes eligible for tax and accounting purposes. A rejected invoice that the issuer does not correct or annul remains issued and the issuer must still record it — which directly affects the tax base.

Only the issuer may correct or annul an invoice, through a new e-invoice referencing the previous one and stating the reason, no later than the submission of the annual VAT return. Delivery notes and return notes are recorded through the system within two days of the transaction. And if the system is down for more than 24 hours, an alternative regime applies: invoices are issued on paper or outside the system and must be submitted to the system within five working days of its restoration — retaining their validity and their original date as authentic.

How high are the fines?

The misdemeanour provisions are graduated by the size of the liable entity and apply to every instance of non-compliance: not using the system, submitting the wrong document type, failing to issue an e-invoice, failing to record related documents, or failing to issue an invoice for a recorded delivery note:

Misdemeanour proceedings are conducted by the Public Revenue Office — the same authority that sees every issuance in real time, making proof of the offence practically automatic.

What should companies change in their contracts and processes?

The change is not only for the accounting department. Contracting practice must be aligned with the new reality, and the most common gaps are precisely in framework agreements signed before the system existed. A minimum checklist:

• register in the PRO system and choose a channel: API integration of the accounting or ERP software, or the client, web or mobile application;
• obtain a qualified electronic signature certificate for the persons who will sign, download and accept invoices;
• a contractual clause that an invoice is deemed delivered once it is available on the system, not when sent by email;
• a clear definition of when the payment period starts to run — from the date of availability on the system — and an internal calendar for the accept-or-reject deadline of the 10th of the following month;
• a review of existing framework agreements with regular suppliers and buyers, especially those with automated invoicing;
• an internal workflow assigning who issues invoices, who checks validation and how a rejected or incorrect invoice is handled;
• own archiving of e-invoices in their original electronic form — the state archive is no substitute: at the PRO, invoices are available for download only two years after the end of the year of issuance;
• an internal plan for alternative invoicing during system downtime (24 hours / 5 working days).

What does the draft law mean for foreign companies and investors?

Foreign companies operating through a branch or a registered entity in North Macedonia are covered in the same way as domestic firms: the obligation follows the tax registration, not the origin of the owner, and invoices issued to foreign persons also enter the system. For investors just entering the market, the reform sends a double signal. Simply registering a company is no longer enough: operational readiness includes tax infrastructure — registration, software and a qualified electronic signature — from day one. At the same time, although the Regulatory Impact Assessment states that the draft is not formally linked to EU directives, the model moves in the direction of the European practice of continuous transaction controls, which gives a serious investor a more predictable environment and less room for grey practices among business partners.

The move to e-Faktura is the biggest change in commercial documentation in decades. Companies that treat it as a technical task for the accounting department will miss the contractual and evidentiary consequences. Those that treat it as a legal change will capture the advantages: cleaner records, a stronger position in debt collection and fewer disputes over what was sent and when. The voluntary period from October 2026 is a rare opportunity to test all of this before it becomes mandatory.

Related service: Corporate Law

Source: Draft Law on Electronic Invoicing — Ministry of Finance draft (public consultation on ENER since 21 August 2026), the Regulatory Impact Assessment Report and the Notification on the Start of the Law- drafting Process.

This text provides general legal information and does not constitute legal advice for a specific case. For advice tailored to your situation, please consult an attorney.