Electronic invoice in Japan

How to Protect Your Input Tax Credit in Japan: A practical guide to the Qualified Invoice System, managing declining transitional deduction rates, and leveraging voluntary Peppol for smoother B2B transactions.

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Overview

Two things in Japan are constantly confused with one another, and almost every misunderstanding starts there. The Qualified Invoice System is a tax regime, in force since 1 October 2023 and mandatory in the sense that full Consumption Tax credit depends on it. Digital invoicing through Peppol and JP PINT is a structured exchange format, and it is entirely voluntary.

The Digital Agency says so plainly: neither using JP PINT nor sending or receiving electronic invoices is mandatory in Japan. A qualified invoice may be paper or electronic, and no invoice template is prescribed as long as the required particulars are present. There is no clearance, no tax fifth corner and no real-time reporting — and no announced date for a B2B or B2G e-invoicing mandate.

0188 / 0221

the Corporate Number and the qualified invoice issuer registration number

JP PINT 1.1.3

published 8 June 2026, in UBL 2.1 — CII is not a supported syntax

7 years

retention for copies of qualified invoices and the corresponding electronic records

Timeline

The dates that matter in Japan are tax dates, not e-invoicing dates — and one of them arrives shortly.

Already in force

September 2021

The Digital Agency becomes Japan Peppol Authority

Taking responsibility for JP PINT, the Japan PA Specific Requirements, accreditation of Japanese service providers and acknowledgement of foreign ones.

1 October 2023

The Qualified Invoice System starts

A registered Qualified Invoice Issuer must, on request from another taxable business operator, provide a qualified invoice and keep a copy — in paper or electronic form. See The Qualified Invoice System.

October 2023

GEPS can receive Peppol invoices

The Government Electronic Procurement System and other central systems completed technical support for receiving Peppol e-invoices — a capability, not an obligation.

1 April 2025

Platform taxation for cross-border B2C electronic services

For qualifying transactions a designated platform may be treated as the supplier for Consumption Tax purposes. A tax mechanism — not an e-invoicing requirement.

8 June 2026

JP PINT 1.1.3

The current version, covering the Peppol BIS Standard Invoice JP PINT, the JP BIS Self Billing Invoice and the JP BIS Invoice for Non-tax Registered Businesses.

Still ahead

1 October 2026

The transitional credit drops from 80% to 70%

For purchases from suppliers not registered as Qualified Invoice Issuers, the deductible equivalent of input tax falls. This is the live commercial pressure in Japan — see Input tax credit.

No mandatory e-invoicing date appears anywhere in this timeline, because none has been announced. Digital Agency and National Tax Agency material published to date sets out no national e-invoicing mandate and no date for one. Roadmaps circulating with a Japanese mandate date are not supported by the official sources.

The Qualified Invoice System

This is the obligation that actually binds. Since 1 October 2023 a registered Qualified Invoice Issuer must, when a taxable business operator asks for one, provide a qualified invoice and retain a copy. The buyer needs it to claim full input Consumption Tax credit.

The document may be paper or electronic — the law prescribes no single template

A qualified invoice can be an invoice, a delivery note, a receipt or another document, provided the required particulars are present — including the supplier's registration number and the tax breakdown

There is no obligation to use Peppol or JP PINT, and no structured B2B e-invoicing requirement

The distinction to hold onto: the Qualified Invoice Issuer registers as a taxpayer, once. Individual invoices are never registered or validated by the tax authority before they reach the buyer. Japan has taxpayer registration, not document clearance.

B2G and GEPS

Since October 2023 the Government Electronic Procurement System (GEPS) and other central government systems have been able to receive Peppol e-invoices. Through 2025 and 2026 the Digital Agency has run GEPS e-invoice user meetings and published details of the services actually used to invoice into GEPS.

But capability is not obligation. No Japanese law requires all public-sector suppliers to issue structured electronic invoices, and none was found in the official material. A supplier may send a Peppol/JP PINT invoice where the particular public recipient and its system support that channel.

GEPS is a government buyer and recipient of invoices — not a tax clearance portal. Sending an invoice into GEPS produces no fiscal validation of any kind.

B2B and B2C

Domestic B2B

For a taxable transaction between Japanese companies: the registered seller provides a qualified invoice on request from a taxable business buyer; the document may be paper, PDF or a structured electronic file; Peppol and JP PINT are used voluntarily; the tax authority receives nothing in real time; and the buyer must retain the invoice and the corresponding accounting records to claim credit. Exchanging a JP PINT document does not by itself secure the credit if the retention and bookkeeping rules are not met.

B2C

No electronic invoice is required for ordinary consumer sales. Retail shops, restaurants, taxis and other businesses dealing with an indeterminate range of customers may issue a simplified qualified invoice, which allows fewer particulars — the buyer's name may be omitted.

The one cross-border exception is B2C electronic services supplied by foreign providers through large digital platforms. From 1 April 2025 platform taxation applies: a designated platform may be treated as the supplier for Consumption Tax and become responsible for the tax and for the qualified or simplified invoice where the conditions are met. Again — a tax mechanism, not mandatory Peppol e-invoicing.

The four-corner model

Japan's infrastructure is the standard Peppol four-corner arrangement — seller, seller's Access Point, buyer's Access Point, buyer — with the structured invoice dataset moving between the two Access Points. The National Tax Agency is not a required participant on the route, and Peppol stores nothing centrally: retention is handled by the parties or by separate commercial services.

Centralised clearanceNo

Tax approval before delivery to the buyerNo

Peppol four-cornerYes — voluntarily

Five-corner with the tax administrationNo

Real-time invoice reportingNo

Mandatory transmission of invoice data to the NTANo

Periodic tax reportingYes — ordinary Consumption Tax compliance

Japanese Peppol e-invoicing is therefore not a CTC or clearance system. That follows directly from the four-corner architecture and from the absence of any tax corner or real-time obligation.

JP PINT and formats

The national specification for a structured Peppol invoice is JP PINT — the Japan implementation of Peppol International Invoice. Version 1.1.3 was published by the Digital Agency on 8 June 2026 in three parts:

Peppol BIS Standard Invoice JP PINTCarries the data corresponding to the particulars of a Japanese qualified invoice

JP BIS Self Billing InvoiceCorresponds to the Japanese purchase statement

JP BIS Invoice for Non-tax Registered BusinessesFor suppliers not registered as Qualified Invoice Issuers

Syntax

UBL Invoice 2.1 and UBL CreditNote 2.1. UN/CEFACT CII is not listed as a supported JP PINT syntax. Since there is no national e-invoicing mandate, UBL 2.1 is not compulsory for all Japanese invoices — it is compulsory only where a message is to be a JP PINT/Peppol message.

JP PINT is not presented as a national implementation of EN 16931. Its normative basis is the global Peppol PINT model plus Japanese localisation. PINT shares many semantic concepts and code lists with the European Peppol model, but OpenPeppol develops PINT as a global specification. So: EN 16931 conformity does not by itself produce JP PINT conformity, and JP PINT conformity should not be presented as formal EN 16931 conformity. Sending into Japan means checking the Japanese business rules, tax categories, identifiers and the JP PINT Schematron.

Where the PDF sits

A PDF can be a perfectly lawful qualified invoice, provided it carries the required particulars — the law prescribes no form or template — and the electronic data is retained under the Electronic Books Preservation Act.

What a PDF is not is a JP PINT e-invoice. It offers no automatic processing, cannot substitute for the UBL document in a Peppol transaction, and attaching a PDF copy of the invoice instead of the structured invoice does not conform to the PINT specification. Both statements are true at once, and keeping them apart is the whole skill of explaining Japan.

Identifiers

JP PINT provides for two Electronic Address Schemes, and which one applies depends on the registration scheme supported and the recipient's capability:

0188Corporate Number of the Social Security and Tax Number System

0221Registered number of the qualified invoice issuer — the Japanese qualified invoice registration number

In practice a Peppol participant may be addressed by the Corporate Number or by the Qualified Invoice Issuer registration number. Supporting both is the safe assumption for an Access Point serving Japanese counterparties.

Peppol in Japan

Peppol is the infrastructure the government chose to standardise on and actively promotes for B2B and B2G. But it is not mandatory, not the only permitted channel, not a replacement for paper, PDF, EDI or bilateral integrations, and not a tax clearance platform.

The Peppol Authority

The Digital Agency, Government of Japan, has acted as Japan Peppol Authority since September 2021. It is responsible for JP PINT, the Japan PA Specific Requirements, accreditation of Japanese service providers, acknowledgement of foreign certified service providers, and liaison with OpenPeppol.

Requirements for providers

Japan runs two different procedures, and confusing them makes the market look far harder to enter than it is. A new Japanese service provider goes through full accreditation. A foreign Access Point already accredited by another Peppol Authority goes through a lighter acknowledgement process.

Japanese service provider — full accreditation

OpenPeppol membership; knowledge of JP PINT and the Japan PASR; a test PKI certificate; technical testing; an interview with Japan PA; the Peppol Service Provider Agreement; a production PKI certificate.

Plus a corporate legal form — "for the time being, corporation only" — a Japanese Corporate Number, a Qualified Invoice Issuer registration number, ISO/IEC 27001 or an equivalent set of measures, and confirmed business continuity arrangements.

Foreign accredited AP — acknowledgement

An approach to Japan PA and an expression of interest; contact details; a signed agreement; the foreign company's registration documents; an ISO/IEC 27001 certificate or equivalent evidence; an individual online interview; and business continuity information if requested.

The interview is in principle conducted in Japanese, though English is permitted with Japan PA's prior agreement.

So certification by a German, Belgian or other EU Peppol Authority does not let you bypass Japan PA — but no full technical re-accreditation is described for such a provider either. The additional step is acknowledgement and inclusion in the Japanese list.

What is not required of a foreign AP

A Japanese company or a Japanese office

A Japanese director, or a local tax representative specifically for Access Point activity

An official electronic mailbox

Connection through a local Japanese Access Point as intermediary

The official Japanese list of recognised service providers confirms this in the most direct way possible: it contains companies accredited by the authorities of Germany, Belgium, Sweden, Denmark, the Netherlands, Australia and elsewhere — SAP, SEEBURGER, ecosio, Avalara/INPOSIA, Billit, Pagero and Storecove among them. Serving Japan from Europe is an established route, not a theoretical one.

Export and ViDA

Exports of goods from Japan, and certain services to non-residents, fall under the Consumption Tax export exemption where the conditions are met. There is no national obligation to send JP PINT or to register an export invoice in any Japanese tax system.

Invoicing a European buyer

—What the contract requires

—The format and capability of the Peppol recipient

—The national rules of the buyer's country

—Whether the seller has an EU VAT registration or establishment

JP PINT and a national European EN 16931 or Peppol BIS localisation may not line up. In practice a conversion from JP PINT into the destination country's format, or generation of the appropriate European invoice profile, will often be needed. That gap is the concrete work in Japan–EU trade.

ViDA

Japan is not an EU member state, so intra-EU is not a category that applies to Japanese domestic transactions, and ViDA creates no automatic obligation for a Japanese company merely because its counterparty is in the EU. A supply straight from Japan to the EU does not become intra-EU. From 1 July 2030 ViDA can reach a Japanese group where a transaction runs through an EU VAT registration, permanent establishment or legal entity and qualifies as a relevant intra-EU transaction — and individual member states' national mandates may bite well before 2030.

Archiving

Copies of qualified invoices and the corresponding electronic records must generally be retained for seven years. Where the invoice was issued or received electronically, the data must be preserved in accordance with the Electronic Books Preservation Act — which is a separate body of requirements from the Qualified Invoice System and is frequently overlooked.

The obligation falls on both sides — the issuer keeps a copy, the buyer keeps the invoice and the accounting records that support the credit

Peppol stores nothing centrally — retention is provided by the parties or by a separate commercial service

Where the transitional deduction percentages are claimed, the corresponding invoice or document must be retained and the required entries made in the books

The practical warning: sending a valid JP PINT dataset does not on its own satisfy the credit conditions. Retention and bookkeeping have to be right as well.

Penalties

There is no penalty for not using Peppol, not using JP PINT, issuing a paper invoice instead of an electronic one, or sending a PDF instead of structured XML — because none of those is mandatory. Japan is one of the few countries on this site where that sentence can be written without qualification.

What is punished

False qualified invoices. It is prohibited to issue a document creating the false impression that it is a qualified invoice when the seller is not registered; to state knowingly false information on a qualified or simplified qualified invoice; or to provide corresponding false electronic records.

Such breaches carry up to one year's imprisonment or a fine of up to JPY 500,000. The exposure attaches to the truthfulness of the document, not to its format.

Input tax credit

Here is where the real commercial pressure sits. Without a qualified invoice and the necessary accounting records, a buyer generally cannot claim full input tax credit. For purchases from suppliers not registered as Qualified Invoice Issuers, a transitional percentage applies — and it is stepping down.

1 Oct 2023 — 30 Sep 202680% of the input tax equivalent — the rate currently in force

1 Oct 2026 — 30 Sep 202870%

1 Oct 2028 — 30 Sep 203050%

1 Oct 2030 — 30 Sep 203130%

After 30 Sep 2031Generally 0%, unless an exception applies

Exceptions exist: certain transactions permit a ledger-only deduction, and for defined small businesses, purchases under JPY 10,000 made before 30 September 2029 are treated separately. So the absence of a qualified invoice does not automatically eliminate the deduction in every case.

Is the electronic invoice the only basis for deduction? No — and neither is the electronic form required at all. Credit needs a qualified invoice or another admissible document, or the corresponding electronic record, plus the accounting entries, compliance with the retention rules, and a supplier validly registered as a Qualified Invoice Issuer. A paper qualified invoice does the job. Peppol and JP PINT are not conditions of deduction.

How we help

Japan is a voluntary market, which changes what "help" means: not compliance rescue, but making the channel work and bridging it to Europe.

JP PINT in UBL 2.1 — Standard Invoice, Self Billing and the Non-tax Registered Businesses profile

Validation against the Japanese Schematron and business rules, and the JP PINT version cadence

Addressing on EAS 0188 and 0221, with the qualified invoice registration number carried correctly

Conversion between JP PINT and European profiles — the gap that actually costs time in Japan–EU trade

Delivery to GEPS and to Japanese public buyers whose systems accept Peppol

Seven-year archiving of the electronic records alongside the invoice

Connection by API, SFTP and CSV, with ERP and IDoc source data

Frequently asked questions

Is e-invoicing mandatory in Japan?

No. The Digital Agency states directly that neither using JP PINT nor sending or receiving electronic invoices is mandatory. What is mandatory is the Qualified Invoice System from 1 October 2023 — but a qualified invoice may be paper or electronic, and no template is prescribed provided the required particulars appear. No date for a national e-invoicing mandate has been announced for B2B or B2G.

Can I serve Japanese clients from my European Peppol Access Point?

Yes, after going through Japan PA's acknowledgement process. It requires an expression of interest, contact details, a signed agreement, your company registration documents, an ISO/IEC 27001 certificate or equivalent, and an individual online interview — conducted in principle in Japanese, with English permitted by prior agreement. No full technical re-accreditation is described. No Japanese company, office, director, tax representative, official mailbox or local intermediary is required, and the official Japanese list already includes providers accredited in Germany, Belgium, Sweden, Denmark, the Netherlands and Australia.

Does JP PINT conformity mean EN 16931 conformity?

No, and the reverse is also false. JP PINT is not presented as a national implementation of EN 16931 — its basis is the global Peppol PINT model with Japanese localisation. PINT shares many semantic concepts and code lists with the European Peppol model, but OpenPeppol develops it as a global specification. EN 16931 conformity does not guarantee JP PINT conformity, and sending into Japan requires checking the Japanese business rules, tax categories, identifiers and Schematron.

Can I send a PDF invoice in Japan?

Yes, and it can be a fully valid qualified invoice provided it carries the required particulars — the law prescribes no form or template, and a qualified invoice can even be a delivery note or receipt. Electronic data must be retained under the Electronic Books Preservation Act. What a PDF cannot be is a JP PINT e-invoice: it offers no automatic processing, cannot replace the UBL document in a Peppol transaction, and attaching it instead of the structured invoice does not conform to PINT.

Which identifier do I register?

Either EAS 0188, the Corporate Number of the Social Security and Tax Number System, or EAS 0221, the registered number of the qualified invoice issuer. Which applies depends on the registration scheme supported and the recipient's capability, so supporting both is the safe assumption for an Access Point serving Japanese counterparties.

Does the tax authority see my invoices?

No. Japan runs a Peppol four-corner model in which the National Tax Agency is not a participant on the route. There is no centralised clearance, no tax approval before the invoice reaches the buyer, no fifth corner, no real-time invoice reporting and no mandatory transmission of invoice data to the NTA — only ordinary periodic Consumption Tax compliance. The Qualified Invoice Issuer registers once as a taxpayer; individual invoices are never registered or validated.

Do I have to send invoices to the government electronically?

No. GEPS — the Government Electronic Procurement System — and other central systems have been able to receive Peppol e-invoices since October 2023, but that is capability rather than obligation. No Japanese law requires all public-sector suppliers to issue structured electronic invoices. You may send Peppol/JP PINT where the particular public recipient's system supports it. GEPS is a government buyer, not a tax clearance portal.

What changes on 1 October 2026?

The transitional deduction for purchases from suppliers not registered as Qualified Invoice Issuers falls from 80% to 70% of the input tax equivalent. It then drops to 50% from October 2028, 30% from October 2030, and generally to zero after 30 September 2031. Claiming the transitional percentage requires retaining the corresponding document and making the required entries in the books. Some exceptions remain — ledger-only deduction in certain cases, and for defined small businesses, purchases under JPY 10,000 made before 30 September 2029.

Summary

Japan is a voluntary Peppol market with a mandatory tax invoice regime — and the two are separate systems that happen to describe the same document. The Qualified Invoice System governs what the invoice must contain and who may issue it; JP PINT governs what a structured version looks like if you choose to send one. Nothing requires you to.

There is no clearance, no fifth corner, no real-time reporting and no announced mandate date. The likeliest direction of travel is continued voluntary Peppol adoption in B2B and the public sector rather than a move to clearance any time soon.

For a European Access Point the practical position is unusually favourable: you can serve Japanese clients directly, without a Japanese entity or intermediary, once Japan PA has acknowledged you. What you need is JP PINT support with the Japanese Schematron, EAS 0188 and 0221, UBL 2.1 between Access Points — and conversion between JP PINT and the European profile your other side requires, since the two do not align by default.

Resources

Digital Agency — JP PINT The Japan Peppol Authority's own English pages on the specification, the PASR and the accreditation and acknowledgement procedures Peppol specifications for JP PINT The technical documentation: syntax bindings, business rules, code lists and the Schematron your validation is built on Peppol Certified Service Providers in Japan The official list — worth reading before assuming Japan needs a local partner, since it is full of European providers OpenPeppol — Japan country profile The Peppol Authority, the three local specifications and the national requirements on service providers National Tax Agency The Qualified Invoice System, the issuer register and the transitional deduction rules for unregistered suppliers Peppol Directory Check whether a Japanese counterparty is reachable — and on which of the two address schemes

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