HMRC consults on e-invoicing digital reporting: what happens after the 2029 go-live?

• On 28 October 2026, HMRC opened a consultation on whether selected e-invoice data could be shared with HMRC for defined purposes after mandatory e-invoicing starts in April 2029. No decision has been taken and there is no preferred model. [gov.uk]
• Under the proposed test, any use of the data must add clear value, keep the burden low and give businesses something back. The consultation also asks whether today’s manual work and reporting could be removed, so that the data does not just create a new obligation on top.
• The consultation runs for 12 weeks and closes on 20 January 2027. It has 29 questions, and respondents do not have to answer them all. Peppol and existing software are assumed to be the routes for sharing the data. [gov.uk]

Extended article

HM Revenue & Customs has launched a consultation on E-Invoicing Digital Reporting. It looks at how information created through e-invoicing could be used more effectively once the UK’s B2B mandate goes live on 1 April 2029. It follows the publication of the UK’s e-invoicing implementation roadmap and is part of the government’s wider work to modernise tax administration. [gov.uk] [gov.uk]

Early and genuinely open

HMRC says clearly that it has not decided whether E-Invoicing Digital Reporting should be introduced, or how it would work. There is no preferred model, and the consultation does not propose that HMRC would receive every invoice. It is meant to gather evidence on the opportunities, risks, costs and safeguards involved. [gov.uk] [gov.uk]

The right test

The consultation sets a clear bar for any use of e-invoice data. It must:

• show clear additional value
• keep the burden on businesses low
• give businesses something in return

It also asks directly whether current manual processes and reporting could be removed rather than having a new obligation added. For multinational groups that already handle several EU reporting regimes, this matters a lot.

Practical use cases

The examples in the consultation are operational rather than theoretical:

• catching errors before they reach the VAT return
• speeding up assurance for VAT repayments
• reducing the number of HMRC information requests

Peppol and existing software as the routes

The consultation assumes data would be shared through Peppol and existing business software. That makes it immediately relevant to software vendors, Access Point providers and finance teams. Whatever is decided will affect how UK e-invoicing systems and ERP integrations are designed before 2029.

Context

This is the next step after HMRC’s earlier consultation, “Promoting electronic invoicing across UK businesses and the public sector”. That consultation already asked whether e-invoicing should be complemented by real-time digital reporting. In response, the government confirmed at Budget 2025 that all VAT invoices would have to be e-invoices from 2029. [simmons-simmons.com] [gov.uk]

How to respond

The consultation closes at 11:59pm on 20 January 2027. Responses can be sent to [email protected]. Indirect tax, finance and e-invoicing practitioners can use it to tell HMRC which uses of the data would genuinely help and which would only add cost. This is especially worth doing for groups that can share lessons from continuous transaction controls (CTC) and e-reporting regimes in other countries. [gov.uk]

Key takeaway: the UK is asking how e-invoice data should be used for reporting before deciding whether to use it at all. Businesses that respond now can help design a system that removes existing reporting work instead of adding to it.

Sources:

• GOV.UK – E-invoicing digital reporting (open consultation)
• GOV.UK – Promoting electronic invoicing: consultation response
• Simmons & Simmons – HMRC publish e-invoicing consultation