UK Finance Bill 2026-27 lays the legal basis for an HMRC Peppol Authority and the 2029 e-invoicing mandate

The Hague, 11 November 2026. The UK government is using the Finance Bill 2026-27 to give HM Revenue & Customs (HMRC) the functions it needs to act as the UK Peppol Authority. This is set out in the HMRC policy paper “VAT: electronic invoicing”, published on 28 October 2026 and updated on 4 November 2026. An HMRC Peppol Authority means that the tax authority will oversee the network over which VAT invoices must be exchanged electronically from April 2029. For Peppol Service Providers active in the United Kingdom, or planning to be, the point of contact for agreements, oversight and country-specific requirements will shift.

Our article of 28 October 2026 on the UK e-invoicing roadmap for 2029 covered the timeline and the PASRs in development. What is new is HMRC as the future Peppol Authority.

What the Finance Bill sets out for an HMRC Peppol Authority

The policy paper states: “The legislation will confer the necessary functions on HMRC to enable it to act as the Peppol Authority.” According to the same document, the UK Peppol Authority sits within Supply Chain Coordination Limited (SCCL), which operates NHS Supply Chain. The timing of the handover is open: “It is not yet determined when HMRC will become the Authority.” The e-invoicing roadmap adds that the timing and governance of the transition are still to be worked out.

The Finance Bill also amends Schedule 11 to the Value Added Tax Act 1994. HMRC will be able to make regulations on when a VAT invoice must be electronic, on “the form and structure of the invoice and the technology, systems and networks to be used”, and on exemptions and transitional provisions. The detailed requirements will follow in secondary legislation.

• Powers in force: from Royal Assent of the Finance Bill 2026-27.
• Requirements in force: “The requirements will have effect from April 2029.”
• Scope: VAT-registered persons and anyone who needs a VAT invoice to recover input tax, including public bodies that are not VAT-registered.
• Costs: HMRC puts its implementation costs at around 19 million pounds; the costs of moving the Peppol Authority are still being quantified. Business cost estimates follow with the secondary legislation.

Not yet known are the date of the handover, any UK accreditation regime, possible penalties and the final UK PASRs.

Peppol Authorities in Europe: tax and non-tax bodies

According to OpenPeppol, a Peppol Authority may define Peppol Authority Specific Requirements (PASRs). These apply automatically to all service providers that serve senders or receivers within that authority’s jurisdiction, wherever the service provider itself is based. More on the role: What is a Peppol Authority?

• France: the Direction générale des Finances publiques (DGFiP) has been the Peppol Authority since 8 July 2025. According to the DGFiP, it can impose different technical requirements through PASRs, for example the obligation to be registered as a Plateforme Agréée.
• Belgium: the FPS Policy and Support (BOSA) has held the role since 1 January 2016. According to a federal government announcement of 25 June 2026, the FPS Finance will take over the role in 2027, largely because of the need for tax expertise with the introduction of e-reporting. Concrete arrangements will be communicated later, in consultation with the parties involved.
• Netherlands: the Netherlands Peppol Authority (NPA) has overseen Peppol on behalf of the government since 2020. The Dutch PASR requires, among other things, valid identifiers (KVK, OIN or VAT number), an ISO 27001 certificate or equivalent statement, and monthly reporting to the NPA.
• Germany: the Koordinierungsstelle für IT-Standards (KoSIT) acts as Peppol Authority on behalf of the IT-Planungsrat. The German Betriebskonzept allows national requirements to be tightened and a national accreditation process to be set up.
• Luxembourg: OpenPeppol lists the Ministry for Digitalisation as Peppol Authority; the OpenPeppol overview of PASRs shows no document for Luxembourg.

France and Belgium show that a tax authority as Peppol Authority can link service provider requirements to the tax framework, such as registration as a Plateforme Agréée or e-reporting. Whether HMRC follows that course is not known; the UK roadmap states that the Peppol Authority will not receive copies of VAT invoices for business transactions.

What it means and what to do now

For Peppol Service Providers with UK customers, or plans to serve them, the supervisor will change and the requirements may change too:

1. Follow the legislation and consultations. Track the Finance Bill 2026-27 to Royal Assent and the secondary legislation. The roadmap announces a public technical consultation in spring 2027 on the proposed UK Access Point Certification requirements.
2. Document your current arrangements. Record which agreement, contacts and reporting arrangements you have with the UK Peppol Authority at SCCL, so that you can follow a handover to HMRC straight away.
3. Expect new or amended UK PASRs. The roadmap mentions identifiers and security among the possible topics. Reserve development and compliance capacity for changes.
4. Keep your basics in order. Check your OpenPeppol membership, your service provider agreement and the registrations of UK end users in your SMP.
5. Plan around the minimum lead time. The UK government commits to at least 12 months’ notice of the e-invoicing requirements. Any required accreditation with the UK Peppol Authority must be completed before 1 April 2029.
6. Prepare for onboarding. Estimate how many UK customers you aim to connect before April 2029 and plan onboarding capacity accordingly.

Sources

1. HMRC, VAT: electronic invoicing (policy paper, 28 October 2026, updated 4 November 2026)
2. HMRC, E-invoicing requirements
3. HMRC, Roadmap for e-invoicing implementation (28 October 2026)
4. OpenPeppol, Peppol Authority Specific Requirements
5. OpenPeppol, Peppol Authorities
6. DGFiP, Rejoindre le réseau Peppol
7. Belgian federal government, Le SPF Finances assumera le rôle d’autorité Peppol belge à partir de 2027 (25 June 2026)
8. OpenPeppol, Country profile Netherlands
9. KoSIT / XEinkauf, Betriebskonzept

If you are preparing for an HMRC Peppol Authority and looking for a service provider with UK coverage, the overview of Peppol suppliers lets you filter by region and functionality.