HMRC have released 'E-invoicing digital reporting: Consultation on the future use of e-invoicing digital reporting'. The consultation seeks views on how introducing electronic invoicing for VAT could improve tax administration and wider public services.

Consultation
From 1 April 2029, E-invoicing for VAT will become mandatory.
- E-invoicing will allow businesses to create, exchange, and process invoices in a standard digital format.
The government is exploring additional uses of e-invoicing in the future.
- This is separate from the ongoing work to introduce e-invoicing in April 2029.
- In some countries, data generated through e-invoicing is reported directly to the tax administration. The government is seeking views on whether there are circumstances where HMRC could receive invoice data in the future.
- For this consultation, digital reporting means sharing, providing or allowing access to selected e-invoice data for defined purposes. HMRC would not automatically receive every e-invoice or all the information an invoice contains.
- Digital reporting is distinct from the requirement to create, issue and receive e-invoices.
- The government believes that this data could:
- Simplify tax administration.
- Support taxpayers to get things right earlier.
- Reduce duplicate reporting and manual processes.
- Improve services.
The government is seeking evidence on whether appropriate access to selected e-invoicing data could:
- Help businesses get their tax right, including through earlier checks and prompts.
- Make VAT repayment checks and compliance activity faster and more targeted.
- Reduce the duplication of reporting, manual evidence gathering and separate information requests.
- Allow software and e-invoicing providers to offer more automated services.
- Support clearly defined wider public functions where there is a justified need, with appropriate data aggregation, governance and safeguards.
The consultation covers five key areas:
- The opportunities created by e-invoicing.
- Potential uses of invoice data and the benefits these might deliver.
- Technology and practical feasibility.
- Cost, risks and safeguards.
- How policy will be developed and the next steps.
The government has not decided to introduce digital reporting, and it has not developed a preferred model yet. The consultation:
- Does not introduce digital reporting.
- Does not change the decisions or announcements already made about mandatory e-invoicing.
- Does not require businesses or software providers to take any preparatory action.
The consultation closes on 20 January 2027. Responses can be submitted through an online survey or sent by email to
Useful guides on this topic
VAT: Autumn Budget 2026
VAT changes announced in the 2026 Autumn Budget include an extension to the online marketplace VAT rules and the zero rate of VAT on domestic electricity. A roadmap outlining the new e-invoicing requirements to be implemented in April 2029 has also been issued.
Input VAT: What constitutes a valid claim (& invoice)?
What is Input VAT? Who can claim it? What is needed for a valid claim? What needs to be included on a VAT invoice and can you make a claim without one?
Registering for VAT
When should a business register for and charge VAT? What are the VAT registration thresholds? What penalties might HMRC issue for late notification of registration? When do you need to file a VAT return?
External link
E-invoicing digital reporting: Consultation on the future use of e-invoicing digital reporting
Consultation Questions
Question 1: Where could the move to structured e-invoicing data create the greatest additional value for businesses, customers and government?
Question 2: What problems, if any, could access to selected e-invoice data help solve? Could the same outcomes be achieved more simply in another way?
Question 3: What risks, limitations or unintended consequences should be considered at this early stage?
Question 4: Where could access to e-invoice data help businesses, software providers or HMRC identify and address errors earlier? What practical difference would this make?
Question 5: What data and level of timeliness would be needed, and who would be best placed to provide prompts or support?
Question 6: What difficulties, delays or administrative burdens arise when businesses or agents provide invoice evidence for VAT repayment assurance?
Question 7: Where could access to relevant e-invoice data improve repayment assurance, and where would further information or context still be required?
Question 8: How could access to e-invoice data reduce or simplify requests for information and reduce unnecessary HMRC interventions?
Question 9: What existing processes, reporting or evidence requirements could realistically be removed or simplified in the VAT return?
Question 10: Where, if anywhere, could appropriately aggregated e-invoice data provide wider public value or reduce duplicated reporting to government?
Question 11: What level of detail or aggregation would be genuinely useful, and what limits should apply?
Question 12: Where, if anywhere, do businesses currently face duplicate, overlapping or inconsistent information requirements from different government departments, and how could e-invoice data help simplify these?
Question 13: What practical benefits would businesses and agents need to receive for any future arrangements to be worthwhile?
Question 14: How might benefits and impacts differ by business size, sector, VAT treatment, digital capability or existing system arrangements?
Question 15: How feasible would it be to use Peppol, existing software or e-invoicing services to make selected32a data available without creating a separate reporting process for businesses?
Question 16: What technical, operational or commercial barriers would need to be addressed?
Question 17: What experience from implementing e-invoicing or digital reporting in other countries should government consider, including impacts on businesses and tax administrations?
Question 18: What relevant capabilities already exist in software, enterprise systems, e-invoicing platforms, standards or networks?
Question 19: How could providers minimise or remove additional work for businesses, and what investment, responsibilities or commercial challenges could arise for providers?
Question 20: What emerging developments in interoperability, automation, analytics or privacy-enhancing technology should government take into account?
Question 21: What should government avoid specifying before use cases and options are better developed?
Question 22: What one-off and ongoing costs or operational impacts could arise for businesses, agents, software providers, intermediaries and government?
Question 23: Where could the use of e-invoice data remove existing costs, duplication or manual processes?
Question 24: What particular issues should be considered for small businesses or organisations with complex, international or legacy systems?
Question 25: What privacy, security, data protection or commercial confidentiality risks should government consider?
Question 26: What safeguards, limitations, governance and assurance would be needed to maintain trust?
Question 27: What transparency and control should businesses have over what data is available, how it is used and who can access it?
Question 28: Are these the right groups and issues for targeted co-creation? Who else should be involved, and what should government seek to learn from them?
Question 29: What evidence, case studies, quantitative data or practical experience should inform the next stage?