HMRC Will Become the UK Peppol Authority for E-Invoicing, and the Government's Roadmap Says the Authority Will Not Receive Copies of VAT Invoices for Business Transactions

HM Revenue and Customs and the Department for Business and Trade published a Roadmap for e-invoicing implementation on October 28, 2026. It restates a decision already made. "From 1 April 2029, VAT-registered persons (including public sector bodies) will need to be able to issue and receive VAT invoices as e-invoices, unless a specific exemption applies." The roadmap defines e-invoicing as "the exchange of structured invoice data directly between buyers' and suppliers' financial systems," and says invoices shared as digital files, but not as structured data, "are not classed as e-invoices." It sets out, it says, when the government will provide further detail on key elements of the regime. Parts of it follow, not the whole.

Taxpayer Obligations

The roadmap says VAT invoices "provide evidence of taxable supplies, support the correct accounting of VAT and enable businesses to recover VAT incurred on their purchases." The new requirement "aims to digitise the existing VAT invoicing process, so does not change the rules on when a VAT invoice must be issued or what it must contain." Other than designated exemptions, VAT-registered organizations will be responsible for issuing compliant e-invoices where a VAT invoice is required, and organizations that receive VAT invoices will also need to be able to receive e-invoices.

On penalties, the government plans, as far as possible, to use the existing VAT invoicing penalties framework as a basis. The roadmap says HMRC's guidance "does not replace, override the law or alter a taxpayer's responsibility to comply with legislation," and that updated VAT guidance will be available by April 2028, "even if this means publishing guidance pending secondary legislation being made."

For a firm that prepares or checks invoices, the plainest line in the roadmap is that the rules on when an invoice is issued and what it must contain do not change. What changes is its form, and the network and software it travels through.

Peppol and the UK Peppol Authority

The government has announced that the UK will adopt Peppol, an international framework for exchanging electronic invoices, as its core interoperability framework for e-invoicing. Organizations will typically reach it through an Access Point provided by their software provider, and Access Point providers "need to be certified before they can operate on the Peppol network." The UK Peppol Authority function currently sits within NHS Supply Chain. "HMRC will become the UK Peppol Authority, taking on responsibility for the governance and oversight of the Peppol framework in the UK," the roadmap says, and further work "will be undertaken to determine the timing and detailed governance arrangements for the transition."

The roadmap says the Peppol Authority "will not receive copies of VAT invoices for business transactions," and adds that "the development of appropriate safeguards and governance arrangements will form a core part of the programme."

It says the government is developing a framework for software providers' responsibilities, which will apply to providers operating within the UK e-invoicing ecosystem, "including software providers that do not operate a Peppol Access Point and are not subject to Peppol accreditation requirements." Its timeline puts the publication of software provider management requirements in Spring 2028, and by April 1, 2029 it expects all software providers operating within the regime to have completed any required accreditation process with the UK Peppol Authority.

The Timeline and Digital Reporting

The government says it will confirm the e-invoicing requirements between October 2027 and April 2028, and launch a public technical consultation on the proposed UK e-invoicing standards in Spring 2027. It is developing an exemption for digitally excluded VAT-registered persons and will publish its details by April 2028.

The roadmap also speaks of digital reporting. At Budget 2026, it says, the government launched a consultation on e-invoicing digital reporting "to explore whether information created through e-invoicing could be used more effectively to support tax administration." The roadmap calls it "an early-stage, exploratory exercise intended to gather evidence and stakeholder views." "No decisions have been taken on whether e-invoicing digital reporting should be introduced," it says. "Any future decisions will be informed by the evidence gathered through the consultation and further analysis."