United Kingdom Opens Consultation on E-Invoicing Digital Reporting
HM Revenue & Customs published a consultation on October 28, 2026, seeking views on whether structured e-invoice data could also support digital VAT reporting. The consultation runs for 12 weeks and closes on January 20, 2027, with businesses able to respond by email or through an online survey.
Scope and Status
The consultation is separate from the United Kingdom’s planned requirement, announced at Budget 2025, for VAT invoices to be issued in a specified electronic format from April 1, 2029. HMRC states that the consultation does not introduce any digital reporting requirement, does not ask businesses or software providers to take any action in anticipation of one, and will not affect decisions already made on the e-invoicing mandate itself. No decision has been taken on whether to introduce digital reporting, and the consultation does not propose a preferred policy or technical model, detailed data requirements, or legislative provisions.
Possible Uses Under Consideration
HMRC’s consultation document sets out several areas where invoice data could potentially be used, including:
- Earlier identification of VAT errors, with prompts to businesses before a return is filed
- Faster or better-targeted assurance around VAT repayment claims
- Fewer information requests and unnecessary interventions
- Aggregated data to support wider public functions, such as economic analysis
- Reciprocal benefits for businesses, with HMRC indicating that proposals imposing costs without clear offsetting reductions in burden would be difficult to justify.
- Use of existing infrastructure such as Peppol, EDI, and current software, to avoid creating a separate reporting process
The consultation poses 29 questions across these themes, along with further considerations regarding technology, feasibility, cost, privacy, and trust. HMRC also plans targeted workshops and roundtables alongside the written consultation. No implementation date has been set for digital reporting, and any further steps would depend on the strength of the case made during this process.
There’s more you should know about e-invoicing in the United Kingdom – learn more about the new and upcoming regulations.
