Image of digital invoice

E-invoicing digital reporting: Consultation on the future use of e-invoicing digital reporting

9 November, 2026

From 1 April 2029, the Government will require VAT invoices to be issued as e-invoices.

HMRC is seeking views on how the structured data created through e-invoicing could be used to deliver benefits for businesses, HMRC and wider Government.

No decision has yet been taken to introduce digital reporting. Any future digital reporting arrangements would be separate from the introduction of e-invoicing requirements from April 2029 and would require separate policy decisions. For the purposes of this consultation, digital reporting means the potential sharing, provision of or access to selected e-invoice data for defined purposes.

The ATT intends to respond to the consultation on the future use of e-invoicing digital reporting. We are particularly interested in hearing about the practical problems and administrative burdens members and their clients currently experience in relation to VAT compliance. You do not need to have experience or detailed knowledge of e-invoicing to respond.

We would particularly welcome practical experience of:

  • VAT repayment checks: What tends to cause delays? What evidence does HMRC routinely request? How much work is involved in gathering and providing it? Are you ever asked to provide information HMRC already holds, or to provide the same information more than once?
  • HMRC compliance checks and information requests: What information are you commonly asked to provide? Which requests involve significant manual work? Are there areas where requests are duplicated or could be simplified?
  • Errors and corrections: What types of errors in VAT records or returns do you see most often? When and how are they usually identified, and what is involved in correcting them?
  • VAT reporting and record keeping: Which parts of the existing process create the most administrative work for businesses or agents? Are there particular difficulties for small and micro businesses?
  • Data and information: Do you encounter problems with inaccurate, incomplete or inconsistent information, including differences between information held by businesses and HMRC? What practical problems does this cause?
  • Existing processes: Are there VAT reporting, record-keeping or HMRC processes which involve unnecessary steps, duplication or manual work?
  • Other practical issues: Are there recurring problems in VAT administration which you think HMRC should be aware of as it considers whether and how e-invoice data might be used in future?

We are particularly interested in understanding the problems you encounter in practice and their impact. For example, how often does the issue arise, how much additional work does it create for the business or agent, does it result in delays or additional costs, and what are the consequences when it occurs? 

Real examples are particularly valuable and can be anonymised. Evidence from members will help the ATT identify the practical issues that should be considered when assessing whether the future use of e-invoice data could improve VAT administration without imposing additional burdens on businesses and agents.

Please send your comments to [email protected] by 11 December. 

Please ensure that any examples provided are anonymised and do not contain information from which an individual client or business could be identified.