Author:
Gavin Barker
Bright Grahame Murray
E: [email protected]
Edited by:
Integra International
Grant Gilmour, B.Sc., MBA, CA, CPA Canada, BC, CPA USA, Az, GDipICL.Sc.
INTEGRA TAX WORLD NEWSLETTER EDITOR
E: [email protected]
E-invoicing Current UK Position
E‑Invoicing in the United Kingdom: Current Position and Policy Developments
This report outlines the current status of e‑invoicing in the United Kingdom, including existing practices, government consultation efforts, and professional recommendations submitted during the consultation process.
Current UK Position on E‑Invoicing
E‑invoicing in the UK is voluntary for most businesses. Adoption varies, with some larger corporations and internationally active businesses already using e‑invoicing solutions. Certain public bodies require electronic invoicing for transactions, creating pockets of mandatory use within the public sector.
HM Revenue & Customs (HMRC) has taken a “wait‑and‑see” approach, monitoring international developments and domestic readiness before committing to a specific model or mandate. As part of this approach, the UK Government launched a consultation titled “Electronic invoicing: promoting e‑invoicing across UK business and the public sector.”
Purpose of the Government Consultation
The consultation sought input on how the UK Government could support broader adoption of e‑invoicing. Areas of interest included:
- Different models of e‑invoicing used internationally
- Whether the UK should adopt a mandatory or voluntary approach
- The potential scope of any future mandate
- Whether e‑invoicing should be accompanied by real‑time digital reporting
The consultation aimed to gather perspectives from businesses, industry groups, technology providers, and professional bodies.
ICAEW Representation (34/25)
The Institute of Chartered Accountants in England and Wales (ICAEW) submitted a formal response (Representation 34/25), reproduced in the presentation with permission. Key recommendations included:
- Adoption of a decentralised model based on established international standards
- Ensuring clarity, consistency, and flexibility in any standards adopted
- Prioritising voluntary adoption initially, with any mandatory rollout considered only after thorough evaluation
- Establishing a clear and realistic timetable for any future mandate
- Approaching real‑time reporting and additional digital services with caution
- Committing to further consultation on detailed implementation issues
These recommendations reflect a preference for gradual, standards‑based development rather than rapid or prescriptive regulatory change.
Consultation Findings
At the time of the presentation, the findings of the UK Government’s consultation had not yet been published. Further updates will depend on the Government’s review of stakeholder feedback and its assessment of the appropriate direction for UK e‑invoicing policy.
Disclaimer
This communication contains general information only based on collective research. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of Bright Grahame Murray, Integra International, related entities, employees or agents shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this communication.
Bright Grahame Murray and Integra International, and their related entities, are legally separate and independent entities.
© 2026 Integra and Bright Grahame Murray
About the Author:
Gavin Barker:
Gavin looks after the complex VAT affairs across a portfolio of clients providing advice on a broad range of VAT issues. He is also responsible for the implementation of Making Tax Digital for VAT within the firm and setting up a new VAT helpline. Prior to joining Bright Grahame Murray, Gavin was Head of VAT at Ayming UK. Away from work, Gavin’s large family takes up a lot of his time, although he does try and find time to play drums and guitar, albeit to ever diminishing ability!
About Bright Grahame Murray:
Our aim is to help clients make the most of the opportunities available to them.
This philosophy has formed the basis of all our services since 1934 when the practice was formed. Today, the comprehensive range of services we provide is underpinned by a partner led service and a reputation for excellence.
We believe in working with our clients in a structured yet flexible way. Each client is assigned to a Client Service Partner who is responsible for co-ordinating all the services we offer.
This partner will work with you to discover your objectives and priorities and draw together the specialist skills and expertise of the most appropriate partners and staff to help you achieve your goals.
The Client Service Partner will monitor the services you receive to ensure that the input from the firm’s specialists is efficiently and effectively integrated. Most importantly, the Client Service Partner will keep in close contact with you throughout the year so as to maintain an overall perspective on your affairs ensuring that you get the best from us now, and as your business grows, in the future.
Bright Grahame Murray is registered to carry out audit work in the UK and regulated for a range of investment business activities by The Institute of Chartered Accountants in England & Wales.
Integra International Bio:
https://integra-international.net/find-an-integra-firm/find-firm-profile/name/bright-grahame-murray/
Bright Grahame Murray:
