Budget 2026: five things the e-invoicing roadmap must answer

The Chancellor delivers the Budget on Wednesday 28 October 2026, and for anyone working on e-invoicing it is the most important date of the year. HMRC's 2026 update to its transformation roadmap says HMRC will work with the Department for Business and Trade to publish a roadmap for the mandate at Budget 2026, setting out the milestones to April 2029.

Here is what we will be looking for on the day.

1. The data standard

Peppol is confirmed as the network, but businesses and software providers need to know exactly what an invoice must contain. Will the UK adopt Peppol BIS Billing 3.0 as it stands, or publish a UK-specific set of rules (a CIUS)? Software vendors need this to plan their builds.

2. Scope at the edges

The headline scope is clear: B2B and B2G VAT invoices. The edges are not. We want to see how the roadmap treats:

• B2C sales, receipts and simplified VAT invoices
• Self-billing arrangements
• Cross-border supplies to and from the UK
• Any thresholds or later start dates for the smallest businesses

3. Provider accreditation

In a decentralised model, service providers do a lot of the work. Who can act as an Access Point for UK invoices, and what standards will they have to meet?

4. Penalties and transition

How will non-compliance be treated in the first months, and what happens to legacy systems that cannot connect to Peppol? The government has said it will keep engaging on legacy systems.

5. The path to reporting

Real-time reporting is off the table at launch. Does the roadmap say anything about whether, or when, invoice data might be reported to HMRC in future?

What if the roadmap is thin?

Even a high-level roadmap would be useful if it fixes dates for specifications, legislation and guidance. We will update this article, the timeline and the mandate guide as soon as the documents are published.