Can a customer refuse an e-invoice? UK VAT rules explained

Yes, under today's rules a VAT-registered customer can refuse electronic invoices. Regulation 13A(2) of the VAT Regulations 1995 says an electronic document is not the VAT invoice "unless the use of the electronic invoice is accepted by the customer". From April 2029 the government has said all VAT invoices must be issued in a specified electronic format, but the law that would remove or change this customer veto has not yet been published.

So for now, consent matters. Here is what the rule says, what it covers, and what we know about how it will change.

What regulation 13A says

Regulation 13A was added to the VAT Regulations in 2004, and paragraphs (2) to (4) were replaced in 2013. The key parts:

Paragraph	What it says
13A(1)	The rule applies where a registered person provides a document "in any electronic format" that purports to be a VAT invoice for services or "relevant goods".
13A(2)	That document "is not to be treated as the VAT invoice required to be provided by the supplier under regulation 13(1) unless the use of the electronic invoice is accepted by the customer."
13A(3)	For self-billed invoices the roles swap: the supplier must accept the customer's electronic self-billed invoice.
13A(4)	An "electronic invoice" is one that contains the regulation 14 particulars and "has been issued and received in any electronic format".
13A(5)	"Relevant goods" excludes goods treated as supplied by an online marketplace operator (section 5A of the VAT Act 1994) and goods whose place of supply is set by section 7(5B), which covers certain imported consignments worth £135 or less.

Two points are easy to miss.

It is not only about structured e-invoices. "Any electronic format" includes an emailed PDF. HMRC's own guidance says the electronic format "may be a structured format such as XML or an unstructured format such as PDF". A customer who refuses electronic invoicing is, strictly, refusing PDFs too.

It is about the VAT invoice, not the commercial document. Regulation 13 requires a VAT-registered supplier to give a VAT invoice to a taxable person, normally within 30 days of the tax point. If the customer has not accepted electronic invoicing, an emailed invoice does not meet that duty, and you would need to provide a paper VAT invoice. Business-to-consumer sales are outside this, because regulation 13 only requires VAT invoices for supplies to taxable persons.

What HMRC's guidance adds

VAT Notice 700/63 puts the rule in practical terms:

• 2.3: "It's up to you whether you issue paper or electronic VAT invoices."
• 4.1: you may invoice electronically where authenticity, integrity and legibility can be ensured "and your customer agrees to receive invoices electronically".
• 4.7: you may want to check that your customer's system can accept your format "before agreeing with them to invoice them electronically".
• 7.2 (the customer's side): "If you do not want, or are not able, to receive electronic invoices you should ask your suppliers to issue you with paper invoices. This is a commercial matter between you and your supplier."
• 2.4: you cannot normally send both paper and electronic versions of the same invoice. Dual running is only allowed during a controlled trial, unless HMRC agrees an exception.

In other words, the current regime is voluntary on both sides. The supplier chooses whether to offer electronic invoices, and the customer chooses whether to accept them.

How is acceptance shown?

Neither the regulation nor the notice prescribes a form of acceptance. Common ways businesses record it:

• a clause in your terms of business saying invoices will be sent electronically
• a tick box or field on your customer set-up form, with the address invoices go to
• a short email from the customer confirming the arrangement
• for self-billing, the written self-billing agreement itself (see self-billing and e-invoicing)

A written record is the safest option, because it is evidence if HMRC ever questions whether an electronic invoice was a valid VAT invoice. This is general information, not tax advice; check Notice 700/63 or ask HMRC if you are unsure.

What changes in 2029

Point	Status
All VAT invoices for B2B and B2G supplies must be e-invoices from April 2029	Confirmed (Budget 2025: "issued in a specified electronic format from April 2029")
The aim is for invoices to be "issued and received electronically"	Confirmed as policy intent (consultation response)
Peppol is the core interoperability network	Confirmed (Tax update 2026, June 2026)
Regulation 13A(2) will be amended or removed	Not yet confirmed: no draft legislation published
Whether buyers will be legally required to be able to receive e-invoices	Not yet confirmed
Transitional rules for customers who cannot receive	Not yet confirmed

The consultation response says the government wants every business, "whichever provider a business selects", to "be able to automatically issue and receive e-invoices when trading with any other UK VAT registered business". That only works if a VAT-registered customer cannot simply opt out, which is why the consent rule is widely expected to change.

The Chartered Institute of Taxation made the same point in its May 2025 consultation response. It said regulation 13A(2) "allows a VAT registered customer to reject the use of e-invoicing" and that "if compulsory mandation takes place, this regulation will need to be amended accordingly." The implementation roadmap is due at Budget 2026 on 28 October 2026. It may say how and when; we will update this page when it does.

Two groups are worth separating:

• Customers who are not VAT-registered are generally outside the mandate. The consultation response says the smallest businesses that are not required to register, and choose not to, "will not be obliged to adopt this technology". See e-invoicing for non-VAT-registered businesses.
• Consumers do not receive VAT invoices under regulation 13 in the first place. See B2C receipts and simplified invoices.

If a customer says no today

Refusals usually fall into one of three types, and each needs a different response.

1. "We want paper." That is their right today. Issue a paper VAT invoice. Avoid also sending an electronic version of the same invoice, because Notice 700/63 treats paper and electronic invoices for the same supplies as a dual system, which is only allowed during a controlled trial.
2. "We don't accept PDFs, use our portal or Peppol." This is not a refusal of electronic invoicing, it is a choice of channel. Today that is a commercial negotiation. You can check whether a customer is already on Peppol with our Peppol Directory lookup.
3. "We want PDFs, not Peppol." Fine today. Plan to raise it again once the roadmap sets dates, because from 2029 a PDF is not expected to count. See does a PDF count as an e-invoice?.

What to do now

1. List customers by how they receive invoices today: paper, PDF, portal, EDI or Peppol.
2. Record acceptance of electronic invoicing for each one, ideally in your terms of business.
3. Flag paper-only customers. They are the ones most affected when the consent rule changes.
4. Ask your software provider whether it can send over Peppol, using our software checklist.
5. Watch the roadmap on 28 October 2026 for the legal change. Our mandate page and timeline will be updated.