U.K. e-invoicing mandate updates

May 2025: U.K. public e-invoicing consultation closes

The U.K. public e-invoicing consultation, announced in September 2024 and published in February 2025, closed on May 7, 2025 after being open for 12 weeks. A date for the publication of the results and findings of the consultation is yet to be announced.

February 2025: U.K. publishes e-invoicing consultation

His Majesty’s Revenue and Customs (HMRC) and the Department for Business and Trade (DBT) published the U.K. e-invoicing consultation on February 13, 2025. The consultation gives businesses the opportunity to share their views on any U.K. e-invoicing regime. The consultation makes clear that the U.K. is not looking to adopt a specific standard but is seeking broader views on how those standards could be used to support e-invoicing adoption and increase the potential benefits. The consultation provides no defined timeline for the adoption of e-invoicing in the U.K.

September 2024: U.K. announces public e-invoicing consultation

U.K. Chancellor Rachel Reeves announces the launch of a public e-invoicing consultation to promote the wider use of e-invoicing and real-time reporting. The consultation seeks to gather feedback from U.K. businesses to better understand how HMRC can support e-invoicing adoption.

March 2022: NHS moves to paperless invoicing

In accordance with the U.K. government’s procurement policy mandating carbon reduction and other environmental considerations, the National Health Service (NHS) moves towards e-invoicing. Suppliers to the NHS are encouraged to use e-invoicing, but it is not compulsory. From March 31, 2022, all invoices submitted to NHS Shared Business Services (NHS SBS) must be submitted electronically via the NHS e-invoicing platform or via Peppol.

Original article published Nov 1, 2022.

While the UK has not mandated B2B or B2G e-invoicing (except for invoicing the National Health Service (NHS)), as part of its VAT system there are formal legal requirements relating to the issuing, receiving and storing of e-invoices. Businesses need to adhere to these where they or their customers have agreed to receive e-invoices on a voluntary basis.

In addition, under HMRC’s ‘Making Tax Digital’ initiative, UK VAT registered businesses must submit their UK VAT return to HMRC via an API using MTD functional compatible software. The only data submitted via the API is the standard summary 9-Box VAT return and there is no e-reporting of individual transactional data or invoices. Transactional level detail for sales and purchases must be stored in digital records in software and be provided to HMRC in the event of an audit, inspection or information request. There is however no specific Standard Audit File for Tax (SAF-T) in the UK. 

As there is no general e-invoicing mandate in the UK, a supplier must always receive the customer’s (the buyer) agreement and acceptance to receive e-invoices. 

There is no explicitly mandated format for an e-invoice in the UK. Businesses are required to ensure the authenticity of the issuer and the integrity of the contents of the e-invoice. However, there is no prescribed method to do this, and general businesses controls are usually accepted. HMRC’s Public Notice does explicitly mention both Advanced Electronic Signatures and Qualified Electronic Signatures as acceptable examples of meeting these requirements (but these are not mandatory). Where the e-invoice is in a machine-readable format e.g., XML, the supplier must provide the ability for human-readability and legibility.

E-invoices (and paper invoices) must be retained for six years after end of the accounting year. While there are no formal archiving requirements, invoices must be stored in such a way as to guarantee their integrity, authenticity and availability during the entire lifetime of the invoice.  HMRC may request physical or remote access to the e-invoice archive or request specific data on electronic media. 

There is no general B2G e-invoicing mandate in the UK. However, the UK has required government departments to be able to receive e-invoices from suppliers. In this regard, Peppol standards (based on the European e-invoicing standard) have been adopted as an acceptable standard for purchase order and invoice messages and are required to be exchanged through Peppol Access Points. The exception to voluntary B2G e-invoicing in the UK relates to supplies to the NHS.

In accordance with the UK Government procurement policy mandating carbon reduction and other social and environmental considerations being integrated into public procurement process, the NHS has moved to full paperless e-invoicing. 

With effect March 31, 2022, all invoices submitted to NHS Shared Business Services (NHS SBS) must be submitted electronically via the NHS’s Tradeshift e-invoicing platform. The platform has Electronic Data Integration (EDI) functionality to enable suppliers to integrate with their existing ERP or invoicing system. It is anticipated that through mandatory e-invoicing, there will a reduction in invoice rejections as there will be invoice data entry validation rules.

As there is no general e-invoicing or fiscalisation mandate in the UK, a supplier must ensure that any invoices or receipts issued to consumers are compliant with UK VAT legislation. In addition, HMRC has recently introduced new powers and penalties to tackle the supply, promotion and possession of electronic sales suppression software and hardware, with penalties of up to £50,000.