VAT-registered persons in the UK, including public sector bodies, must be able to issue and receive VAT invoices as e-invoices from 1 April 2029, under a roadmap released alongside the Autumn Budget.
UK’s HM Revenue & Customs (HMRC) published an e-invoicing implementation roadmap on 28 October 2026, setting out when VAT invoices must become e-invoices, the role of Peppol and the steps businesses should take next. Unless a specific exemption applies, VAT-registered persons must issue and receive VAT invoices as e-invoices from 1 April 2029.
The government will confirm the full requirements between October 2027 and April 2028, giving software providers, businesses and public bodies at least 12 months to prepare.
Who is in scope?
The requirement will apply broadly to VAT-registered businesses, sole traders, partnerships, Scottish Partnerships, charities and public bodies. It covers taxable supplies between VAT-registered persons within the UK where a VAT invoice is already required. Non-established taxable persons will follow the same rules as UK-based entities.
E-invoices will not be mandatory for sales to consumers, supplies by non-VAT-registered businesses or cross-border transactions, though these parties may adopt them voluntarily. Exemptions will be tightly limited, mainly for digitally excluded persons, using criteria similar to those under Making Tax Digital (MTD) for VAT. Details are due by April 2028.
PDF, JPEG, HTML and fax images do not qualify. The roadmap defines an e-invoice as structured invoice data exchanged directly between buyers’ and suppliers’ financial systems.
Peppol at the core
The UK will adopt Peppol as its core interoperability framework, with businesses generally connecting through certified Access Points offered by their software providers. HMRC will become the UK Peppol Authority, taking over the function currently held within the NHS Supply Chain. The authority will not receive copies of VAT invoices for business transactions.
Key dates
- Spring 2027: public technical consultation on e-invoicing standards and Access Point certification
- October 2027 to April 2028: publication of scope, exclusions, standards, guidance, business identifiers and software provider requirements
- Summer 2028: readiness testing with software providers
- Winter 2028: infrastructure and governance arrangements operational
- 1 April 2029: requirement takes effect
Legislation
Primary legislation will be introduced through Finance Bill 2026 and is expected to become law in Spring 2027. Secondary legislation carrying the detailed rules may not be concluded until Autumn 2028 or early 2029. HMRC plans to publish updated VAT guidance by April 2028, even if secondary legislation is still pending.
Why the government is acting
Late payments cost the UK economy GBP 11 billion a year, according to the roadmap, and small businesses spend an average of 86 hours annually chasing them. Industry research suggests the smallest businesses could save five hours and 40 minutes a week through e-invoicing. NHS Shared Business Services reports that electronic invoices are paid 26 days faster than paper or email invoices.
The roadmap adds that e-invoicing can help reduce invoice fraud, for instance by checking bank details against those previously used by the same supplier. Many small and medium enterprises may not need new software, as several providers plan to include e-invoicing in existing packages at no extra cost.
What businesses should do now
HMRC says there is no need to begin implementation before the detailed requirements are published. It suggests that businesses review current invoicing processes, brief their finance, tax, procurement and digital teams, speak to accountants or advisers, and research software providers.
HMRC has also launched a consultation on e-invoicing digital reporting, stressing that no decision has been taken on introducing it. Stakeholders can contact [email protected] to take part in policy and standards work.
