UK e-invoicing roadmap sets the 2029 timeline for Peppol, standards and software provider accreditation

The Hague, 28 October 2026 | Alongside Budget 2026, HM Revenue & Customs (HMRC) and the Department for Business and Trade have published the Roadmap for e-invoicing implementation. The UK e-invoicing roadmap sets out when the government will take each decision ahead of the mandate on 1 April 2029. For software providers it is the first plan they can align product development with: from technical consultations in spring 2027 to any required accreditation with the UK Peppol Authority before 1 April 2029.

What the UK e-invoicing roadmap confirms

From 1 April 2029, VAT-registered persons, including public sector bodies registered for VAT, must issue and receive VAT invoices as e-invoices. The requirement applies across the public and private sectors. Sales to consumers (B2C), exempt, zero-rated and out-of-scope transactions, and cross-border transactions are outside the requirement; for those, a commercial e-invoice may still be sent voluntarily. Non-established taxable persons will be subject to the same invoicing requirements as UK-based entities.

Exemptions will be tightly defined. For digitally excluded VAT-registered persons, the government will follow the approach already used for Making Tax Digital (MTD) for VAT. Peppol is the core interoperability framework, as the government announced at Tax Update Day 2026 in June 2026. The UK Peppol Authority function currently sits within NHS Supply Chain, and the UK Peppol Authority will not receive copies of VAT invoices for business transactions. On penalties, the government plans to use the existing VAT invoicing penalties framework as a basis as far as possible.

Milestones in the roadmap

• Spring 2027: public technical consultations on UK e-invoicing standards and on Access Point Certification requirements; decision on the long-term location of the UK Peppol Authority; primary legislation through Finance Bill 2026 expected to become law.
• Autumn 2027: further guidance on EDI and legacy systems.
• End of 2027: guidance for specific VAT-registered populations.
• October 2027 to April 2028: full requirements published, including scope, exclusions, standards, business identifiers and service provider requirements.
• By April 2028: details of the digital exclusion exemption, taxpayer obligations and updated VAT guidance.
• Spring 2028: Software Provider Management requirements, including whether additional authorisation, accreditation or assurance applies and how this relates to OpenPeppol governance.
• Summer 2028: readiness testing with software providers.
• Autumn 2028 or early 2029: secondary legislation may be concluded.
• Winter 2028: infrastructure and governance arrangements operational.
• 1 April 2029: mandate starts; software providers are expected to have completed any required accreditation with the UK Peppol Authority.

Context: legislation, identifiers and open questions

Current UK VAT law permits e-invoicing but cannot mandate it. The government will therefore introduce primary legislation in Finance Bill 2026, with detailed rules following in secondary legislation. It commits to at least 12 months’ notice of the requirements. Peppol.nu covered the Peppol decision in UK Confirms Peppol as Core Network for Mandatory E-Invoicing in 2029 (29 June 2026) and the background in the guide UK einvoicing mandate starting April 2029.

Every user will register a business identifier as part of their Peppol participant identity. Which identifiers will be accepted is still to be decided, and the UK has no single identifier that covers all organisation types. UK Peppol Authority Specific Requirements (PASRs) are also in development. The link to digital reporting to HMRC remains open: HMRC will continue to explore it, and the roadmap contains no decision on this point.

What it means and what to do now

For every software provider whose customers invoice in the UK, planning now follows the milestones above. The roadmap states that businesses do not need to begin implementing before the detailed requirements are published, but architecture decisions for software providers take longer.

• Decide your Peppol route: your own OpenPeppol certification as a Peppol service provider, or connecting through a partner’s Access Point. Businesses will not need to become Access Points themselves and are likely to connect through their existing software provider.
• Respond to the spring 2027 consultations on standards and Access Point Certification. To take part in policy development and testing, contact einvoicingengagement@hmrc.gov.uk.
• Keep your data model flexible for business identifiers until the decision between October 2027 and April 2028, and plan Peppol registration for each customer.
• Build scope logic: separate in-scope VAT invoices from B2C, exempt and cross-border transactions, and treat customers established outside the UK with a UK VAT registration as in scope.
• Run EDI and Peppol side by side: EDI can continue, but your customers must also be able to exchange e-invoices through the Peppol framework. Follow the autumn 2027 guidance.
• Connect e-invoicing with MTD for VAT for SME customers; the roadmap notes that several e-invoicing providers also provide MTD software.
• Reserve release capacity for readiness testing in summer 2028 and complete onboarding, assurance and any accreditation between winter 2028 and 1 April 2029.

For businesses

Any business with a UK VAT registration is in scope, including businesses established outside the UK. The roadmap advises against implementing ahead of the detailed requirements, but suggests researching the market of e-invoicing software providers and speaking to an accountant or adviser.

For Peppol service providers

Follow the spring 2027 consultation on Access Point Certification and the PASRs, which may cover identifiers, security, reporting, service levels, local interoperability and accreditation. The Software Provider Management publication in spring 2028 will settle whether additional UK requirements apply on top of OpenPeppol certification.

Sources

1. HM Revenue & Customs and Department for Business and Trade, Roadmap for e-invoicing implementation, 28 October 2026.
2. GOV.UK, E-invoicing implementation Roadmap (publication page), 28 October 2026.
3. GOV.UK, Budget 2026, 28 October 2026.
4. OpenPeppol, UK Government Announces Peppol as Core Interoperability Network for Future eInvoicing Framework, 24 June 2026.

For software providers, the UK e-invoicing roadmap turns 2029 into a question of choosing in good time between your own Access Point and a partner. To support that choice, compare Peppol service providers and their features in the overview of Peppol suppliers on peppol.nu.