Regulatory updates - United Kingdom

On October 28, 2026, HMRC published the roadmap for e-invoicing implementation alongside the Autumn Budget. It sets out the key dates, clarifies the scope and role of Peppol as well as outlines the next steps for businesses.

Scope

From April 1, 2029, VAT-registered persons will have to issue and receive VAT invoices as e-invoices unless an exemption is applicable to them. HMRC confirmed that the obligation will also extend to non-established taxable entities registered for UK VAT.

The mandate intends to follow the existing VAT invoicing rules meaning that an e-invoice is required wherever a VAT invoice is required today, primarily for taxable supplies between VAT-registered persons in the UK.

Consumer sales and cross-border transactions are outside the mandate, although businesses may use e-invoices for them voluntarily.

Key dates

The roadmap also provides an implementation schedule leading up to the April 2029 go-live date:

• Spring 2027: Consultation on the technical framework and introduction of enabling legislation
• October 2027 to April 2028: Publication of detailed requirements, including scope, exemptions, technical standards, business identifiers for Peppol registration, and software provider obligations
• Summer 2028: Readiness testing with software providers
• Winter 2028: Governance, onboarding, and operational infrastructure become fully available
• April 1, 2029: Mandatory e-invoicing becomes effective

Technical framework

The roadmap confirms that UK will implement mandatory e-invoicing through Peppol based four corner interoperability model, with businesses exchanging e-invoices through certified Access Points. Invoices must be structured data, so PDFs, word documents or email invoices do not qualify.

HMRC will become the UK Peppol Authority, taking over from NHS Supply Chain. The timing and governance of the transition are still to be determined.

Businesses with EDI or legacy systems may keep them, provided they can also exchange e- invoices through the UK's Peppol-based network for transactions subject to the mandate. Further policy and technical work will determine how this will operate in practice.

Digital reporting

The roadmap does not introduce a digital reporting obligation. At Budget 2026, the government launched a consultation seeking views on the potential future use of digital reporting and how information created through e-invoicing could be used more effectively. HMRC has emphasized that no decision has been taken regarding the introduction of digital reporting and that the consultation is intended solely to inform future policy developments. Stakeholders are invited to contribute to the consultation by January 20, 2027.

Next steps

The UK Authorities have committed to confirming the full requirements between October 2027 and April 2028, giving businesses and service providers at least 12 months to prepare. Businesses may nonetheless already start preparing by mapping invoice flows, checking customer and supplier data, and initiating conversations with their service providers.

The announcement forms part of the broader 'Tax Update 2026: Simplification, Modernization and Fairness' policy paper published by the UK authorities on June 23, 2026. The policy paper sets out a package of tax and customs measures designed to reduce administrative burdens, improve certainty, fairness, and customer experience.

Within this update, the government announced that Peppol will underpin the UK's e-invoicing framework, providing software developers and businesses with a clear direction ahead of the 2029 mandate and enabling them to begin planning their product development and e-invoicing rollout accordingly. The government has also committed to ongoing engagement with stakeholders on the future role of legacy systems that are unable to interoperate within the new framework.

On November 26, 2025, as part of the UK Budget 2025, the Chancellor confirmed the removal of the £135 customs duty exemption for low-value imports. The change will apply to all commercial consignments currently benefiting from this relief and is expected to be fully implemented by March 2029.

The Government has launched a consultation on the new compliance framework, which includes:

• Item-level data requirements for customs declarations.
• Shifting compliance responsibility to marketplaces and sellers, with potential UK fiscal representative obligations for non-established businesses.
• Integration of customs duty collection with VAT processes to streamline reporting.
• Replacement of the current BIRDS model with a new LVI customs system designed for high-volume, low-value flows.

This reform aligns the UK with international trends, including the EU’s plan to abolish the €150 de minimis threshold and the US tightening of its $800 exemption. The move is intended to protect revenue, reduce undervaluation risks, and create a level playing field for domestic retailers.

The consultation is currently open and will close on March 6, 2026.