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Japan e-Invoicing Mandate

This guide provides an overview of e-Invoicing requirements in Japan, including the legal framework, the use of the QIS: Qualified Invoice System for Japan, compliance obligations, and key reporting considerations. It is intended to assist businesses that issue or receive invoices for transactions subject to Japanese Consumption Tax (JCT).

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Tax Authority

NTA & Digital Agency

Mandate Go-Live Date

1 October 2023

Digital Signature

Not required

Archiving

Mandatory - 7 Years

Invoice Format

JP PINT, JP Self/Non-tax Invoice, PDF

Japan introduced the Qualified Invoice System on 1 October 2023 as part of reforms to the Japanese Consumption Tax regime. Under this system, buyers generally need to retain qualified invoices issued by registered qualified invoice issuers in order to claim input tax credits. Japan does not operate a clearance or real-time reporting model; invoices are exchanged directly between suppliers and buyers without prior validation by the National Tax Agency.
 
Japan’s Digital Agency acts as the Peppol Authority and promotes the JP PINT specification for structured electronic invoicing, but the use of e-Invoicing remains voluntary. Separately, under the Electronic Books and Records Preservation Act, businesses that exchange transaction information electronically must retain that data in compliant electronic form. As a result, Japan has a mandatory qualified invoice and electronic record retention framework, but not a mandatory e-Invoicing regime.
Mandate Details
Mandate Status
Which types of transactions must be reported via e-Invoicing?
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Effective: October 2023

E-invoicing (as a format) is voluntary.
 
Qualified Invoice System (QIS) in force from 1 October 2023.
 
Electronic record retention required for electronically received transaction data.

B2B (Domestic): In scope where the buyer claims input tax credit (qualified invoice required).

B2C (Domestic): Not generally in scope for input tax credit; simplified qualified invoices apply in certain sectors.

B2G (Domestic): In scope where JCT applies (same QIS rules as B2B).

Cross-border: Not subject to a domestic e-Invoicing or reporting mandate; import JCT handled via customs documentation.

Japan does not require clearance or real-time reporting to the tax authority.

Are there any thresholds that determine e-Invoicing applicability?

  • No, there is no threshold applicable.
  • Taxpayers who adopt the flat-rate regime
  • Third sector entities with revenue/fees of EUR 65,000 and over
  • Microenterprises with revenue/fees of EUR 25,000 and over
  • All taxable persons, residents or established, in Italy if their annual revenue is above EUR 25,000
  • Amateur sports associations

What are the implementation dates of the e-invoicing mandate?

Transaction Type
1 Oct 2023 (QIS Go-Live)
1 Jan 2024 (ERRL)
1 October 2026 (50% of transitional credit)
30 Sept 2029 (End of transitional credit)
Local - B2G (Public)
*
Local - B2B (Domestic)
*
**
Local - B2C (Domestic)
Local - Cross-border reporting
Foreign - B2B/B2C (non-established)
*
***
Mandatory requirement in effect
*
Qualified Invoice required for buyer to claim JCT input credit
**
Peppol JP PINT technical framework alignment/update
***
Transitional credit reduction phase (input credit reduced to 50%)
Not mandatory
Do I need to have a permanent establishment in Japan to be required to e-invoice?
The obligation applies to all JCT-registered taxpayers, including non-established entities registered for JCT in Japan.
 
Domestic established businesses: In scope.
 
Foreign businesses registered for JCT (non-established): In scope.
 
Businesses not registered for JCT: Not permitted to issue qualified invoices.

Permanent establishment is not the trigger; JCT registration status is.

Yes


Only businesses registered with the Japanese National Tax Authority (NTA) as qualified invoice issuers may issue qualified invoices. Buyers may only claim input JCT credits if the invoice is issued by a registered qualified invoice issuer. This applies to B2B, B2C, B2G, and cross-border transactions within scope.

There is no real-time submission requirement to the tax authority. Invoices must be issued within 30 days from the transaction date. No pre-clearance or reporting to NTA required at issuance stage.

If a supplier does not issue a compliant qualified invoice (including JCT registration number), the buyer cannot claim input tax credit.

Non-compliance with electronic archiving rules may result in administrative penalties.

Failure to register as a qualified invoice issuer prevents issuance of valid qualified invoices.

Steps to be performed by customer

1. Register with the Japanese National Tax Authority (NTA) as a qualified invoice issuer and obtain a JCT registration number.

Steps VAT IT can assist with

2. Implement invoicing processes compliant with the Qualified Invoice System (include required JCT data fields).
3. If using structured exchange, implement Peppol JP PINT format via an accredited Access Point.
4. Ensure invoices include required elements (JCT number, tax rate, tax amount per rate category).
5. Implement compliant electronic archiving under ERRL (timestamp, search functionality, immutability controls).
6. Retain invoices electronically for 10 years (storage permitted abroad if accessible).

FAQs

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Staying compliant involves understanding local VAT regulations in different countries, maintaining accurate records, and using the right documentation. VAT IT offers expertise in these areas, ensuring that your VAT reclaim processes align with regulations in each jurisdiction.

Staying compliant involves understanding local VAT regulations in different countries, maintaining accurate records, and using the right documentation. VAT IT offers expertise in these areas, ensuring that your VAT reclaim processes align with regulations in each jurisdiction.

Staying compliant involves understanding local VAT regulations in different countries, maintaining accurate records, and using the right documentation. VAT IT offers expertise in these areas, ensuring that your VAT reclaim processes align with regulations in each jurisdiction.

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