- Business terms
- BT-31 Seller VAT identifier BT-48 Buyer VAT identifier
- Published
In short: From 1 April 2029 the UK requires VAT invoices between VAT-registered businesses in the UK to be issued as structured e-invoices, and every VAT-registered business must be able to receive e-invoices from that date. Exchange runs over the Peppol network. HMRC and the Department for Business and Trade published the roadmap on 28 October 2026; standards, exemptions and identifiers follow between October 2027 and April 2028. PDF, Word or emailed invoices do not count as e-invoices.
The topic is also searched as UK e-invoicing mandate, HMRC e-invoicing, Making Tax Digital e-invoicing, Peppol UK or mandatory e-invoicing UK 2029.
At a glance
| Question | United Kingdom (roadmap 28 Oct 2026) |
|---|---|
| Start | 1 April 2029, one date for everyone – no phasing by business size |
| Who | All VAT-registered persons: companies, sole traders, partnerships, charities and public bodies |
| Which invoices | Domestic taxable supplies between VAT-registered persons that need a VAT invoice today (B2B and B2G) |
| Out of scope | Invoices to consumers (B2C) and cross-border invoices |
| Network | Peppol via certified Access Points; HMRC receives no invoice copies |
| Format | Still open: Peppol-based international standards plus a limited number of UK-specific requirements (consultation spring 2027) |
| Reporting to HMRC | No real-time reporting at the start; digital reporting is still being explored |
| Exemptions | Narrow: digitally excluded persons and technical edge cases; details by April 2028 |
Who is in scope?
The mandate follows the existing UK invoicing rules: where a VAT invoice must be issued today, it must be an e-invoice from April 2029. When an invoice is due and what it must contain does not change – only its form.
- Issuing: every VAT invoice for a taxable supply to another VAT-registered business in the UK.
- Receiving: all VAT-registered persons must be able to receive e-invoices.
- Non-established taxable persons registered for UK VAT are treated like UK businesses: a UK supply to a VAT-registered customer needs an e-invoice.
- Businesses not registered for VAT may use e-invoicing voluntarily but do not have to.
What counts as an e-invoice?
In the roadmap an e-invoice is structured invoice data exchanged directly between the systems of supplier and buyer. Invoices shared only as digital files without structured data – PDF, Word, JPEG, HTML, email or fax – are explicitly not e-invoices. Hybrid formats such as ZUGFeRD or Factur-X (PDF/A-3 with embedded XML) are not mentioned; exchange is meant to run over the Peppol network.
Peppol and standards
The government confirmed Peppol as the core interoperability framework at Tax Update Day 2026. Businesses usually connect through a certified Access Point, typically provided by their software provider. Certification runs through OpenPeppol; the UK Peppol Authority currently sits within NHS Supply Chain, and a decision on its long-term home is due in spring 2027. It will not receive copies of business invoices.
The roadmap does not yet fix a syntax or a field list. It says the UK will build on established international standards, "including those used in Peppol", and add a limited number of UK-specific requirements. For orientation: today's Peppol invoice format Peppol BIS Billing 3.0 implements the European standard EN 16931 and mostly uses the UBL 2.1 syntax – the same standard behind XRechnung, ZUGFeRD and Factur-X (syntaxes compared).
The Peppol identifier is open as well: every business must register a business identifier. As the UK has no single number for all organisation types, the government will decide between October 2027 and April 2028 which identifiers are accepted.
Roadmap to 2029
| When | What |
|---|---|
| Spring 2027 | Public technical consultation on standards and Access Point certification; decision on the home of the Peppol Authority; primary legislation via Finance Bill 2026 (subject to Parliament) |
| Autumn 2027 | Guidance on EDI and legacy systems |
| By end of 2027 | Guidance for specific taxpayer groups |
| October 2027 – April 2028 | Scope, exclusions, standards, business identifiers and requirements for software providers |
| By April 2028 | Digital exclusion exemption, taxpayer obligations, updated VAT guidance |
| Spring 2028 | Software provider requirements, including any accreditation |
| Summer 2028 | Readiness testing with software providers |
| Winter 2028 | Infrastructure and governance operational |
| Autumn 2028 – early 2029 | Secondary legislation |
| 1 April 2029 | Mandate takes effect |
The government commits to at least 12 months' notice: full details are due 12 to 18 months before the start.
Compared with Germany and France
| Germany | France | United Kingdom | |
|---|---|---|---|
| Receiving | since 1 Jan 2025 | since 1 Sep 2026 | from 1 Apr 2029 |
| Issuing | 2027 (turnover above €800,000), 2028 all | large and mid-sized companies since 1 Sep 2026, small ones from 1 Sep 2027 | all from 1 Apr 2029 |
| Formats | XRechnung, ZUGFeRD from BASIC | Factur-X, UBL, CII | Peppol-based, details open |
| Reporting to the state | no | yes, via approved platforms | not at the start |
Details on Germany: e-invoicing mandate in Germany.
Common misconceptions
- "We already email PDFs." From April 2029 that no longer counts as an e-invoice – not even if the PDF was generated by software.
- "We supply from abroad, so this affects us." Cross-border invoices to UK customers are out of scope. You are in scope if you are registered for UK VAT and make UK supplies to VAT-registered customers – and every VAT-registered business, including registered foreign businesses, must be able to receive e-invoices from UK suppliers.
- "We will wait for the final specifications." Between the details (by April 2028) and the start there are only 12 to 18 months. Master data, processes and an Access Point connection can be prepared today.
- "The platform will fix our invoicing problems." An Access Point only transports. Missing or wrong data – for example the seller's (BT-31) and buyer's (BT-48) VAT numbers – must be right in your own system first.
What businesses can do now
- Check scope: which invoices are domestic B2B or B2G VAT invoices in the UK? Is there a UK VAT registration?
- Structure the data: mandatory details such as VAT number, addresses, VAT rates and payment data must exist as fields, not only in the invoice layout.
- Plan the Peppol connection: ask your software or ERP provider whether and when a certified Access Point will be available.
- Use EN 16931 as the basis: invoice data mapped and validated against EN 16931 today covers most of the work for Peppol.
- Track the dates: consultation in spring 2027, requirements between October 2027 and April 2028.
What it means for developers using the Aloaha ZUGFeRD SDK
The SDK creates EN 16931 e-invoices in the CII syntax (XRechnung, ZUGFeRD, Factur-X), reads UBL invoices and validates invoices against the EN 16931 rules (beta). The data model of the standard – business terms such as BT-31 or BT-48 – is the same for Peppol. Applications that map their data cleanly to EN 16931 today can reuse it for the UK format later; sending via Peppol is done by an Access Point. Once the UK standards are final we will assess what the SDK needs in addition.
Sources
- GOV.UK: Roadmap for e-invoicing implementation (HMRC and Department for Business and Trade, 28 October 2026)
- GOV.UK: Promoting electronic invoicing across UK businesses and the public sector – consultation response
Frequently asked questions
When does mandatory e-invoicing start in the UK?
On 1 April 2029. From that date VAT invoices between VAT-registered businesses in the UK must be e-invoices, and all VAT-registered businesses must be able to receive them. There is no phasing by business size.
Is Peppol mandatory in the UK?
Peppol is the core exchange framework. Businesses connect through a certified Access Point, usually via their software provider. EDI and legacy systems may continue, but businesses must also be able to exchange e-invoices over Peppol.
Is a PDF invoice by email still enough in the UK from 2029?
No. PDF, Word, images, email or fax without structured data are not e-invoices. The roadmap does not say whether hybrid formats such as ZUGFeRD are accepted; exchange is planned over Peppol.
Do suppliers outside the UK have to send e-invoices to UK customers?
The roadmap does not require e-invoices for cross-border transactions. A business registered for UK VAT that makes UK supplies to VAT-registered customers is treated like a UK business.
Which format will the UK use?
That is not decided yet. The government will build on Peppol standards and add a limited number of UK-specific requirements; the consultation is planned for spring 2027 and the details follow between October 2027 and April 2028.
Do e-invoices have to be reported to HMRC?
Not at the start. HMRC continues to explore digital reporting of invoice data but has not decided. The Peppol Authority does not receive invoice copies.