# Haulage e-invoicing: freight, self-billing and the 2029 mandate

> What the April 2029 e-invoicing mandate means for hauliers, couriers and forwarders: freight VAT, self-billed subcontractors and customs disbursements.

- Canonical URL: https://einvoices.uk/news/e-invoicing-logistics-haulage
- Published: 20 October 2026 (2026-10-20)
- Last updated: 20 October 2026 (2026-10-20) (not updated since publication)
- Author: Floris Lindenaar, Editor, e-invoicing expert (https://einvoices.uk/authors/floris-lindenaar)
- Publisher: einvoices.uk (https://einvoices.uk)
- Type: Guide
- Topics: Sectors, 2029 mandate, VAT, Small business
- Language: en-GB (UK English); covers the United Kingdom

## Sources

- [Freight transport and associated services (VAT Notice 744B)](https://www.gov.uk/guidance/vat-on-freight-transport-and-associated-services-notice-744b)
- [Self-billing (VAT Notice 700/62)](https://www.gov.uk/guidance/self-billing-notice-70062)
- [VAT guide (VAT Notice 700)](https://www.gov.uk/guidance/vat-guide-notice-700)
- [Peppol BIS Self Billing](https://docs.peppol.eu/poacc/self-billing/3.0/bis-sb/)
- [Tax update 2026: simplification, modernisation and fairness summary](https://www.gov.uk/government/publications/summary-of-tax-update-2026-simplification-modernisation-and-fairness/tax-update-2026-simplification-modernisation-and-fairness-summary)

---

Most haulage invoices are B2B. Hauliers, couriers and freight forwarders sell to other businesses, so if you are VAT-registered and your customer is too, your VAT invoices will need to be **e-invoices from April 2029**. The sector also has three complications to plan for: **zero-rated and out-of-scope** international work, widespread **self-billing** of subcontractors, and **customs disbursements**.

## Which haulage invoices are in scope

| Work | VAT treatment (summary) | 2029 position |
|---|---|---|
| Domestic haulage for a UK VAT-registered customer | Standard-rated | **In scope** |
| Haulage for a council, NHS body or department | Standard-rated | **In scope** (B2G) |
| Import or export leg where the place of supply is the UK | Zero-rated, with evidence | **Not yet confirmed** (VAT invoices are not required for zero-rated supplies) |
| Freight for a business customer that belongs outside the UK | Outside the scope of UK VAT | **Not yet confirmed** (no UK VAT invoice) |
| Owner-driver subcontractor, self-billed by you | Standard-rated, invoice raised by customer | Expected in scope; UK self-billing rules not yet published |
| Delivery to consumers (for example a parcel courier's B2C service) | Standard-rated, no VAT invoice needed | Out of scope (B2C) |

## VAT on freight: the rules behind the table

[VAT Notice 744B](https://www.gov.uk/guidance/vat-on-freight-transport-and-associated-services-notice-744b) sets out the treatment.

**Place of supply.** Freight transport and related services to a customer "in business" fall under the B2B general rule: the place of supply is where the **customer belongs**. If that is outside the UK, the supply is outside the scope of UK VAT, although you can still recover related input tax. HMRC gives an example of how this works for a subcontractor. If a French company moves goods from Italy to Ireland for a UK company, the place of supply is the UK. But a UK haulier subcontracted by the French company to move the goods from Dover to Holyhead is supplying the French company, so the place of supply is France.

**Imports and exports.** Where the place of supply is the UK, transport that forms part of an **import or export** movement can be **zero-rated**. You need commercial documents as evidence linking your service to a specific import or export. HMRC's list includes sales invoices among the possible evidence. Transport after the goods reach their destination, or of goods not yet consigned for export, is not zero-rated.

**Why this matters for e-invoicing.** [VAT Notice 700](https://www.gov.uk/guidance/vat-guide-notice-700) says VAT invoices are not required for zero-rated supplies, and out-of-scope supplies carry no UK VAT at all. The mandate is framed around VAT invoices. It is **not yet confirmed** whether zero-rated or out-of-scope freight invoices must also be e-invoices. In a structured invoice, zero-rated lines use category **Z** and out-of-scope lines category **O**. An invoice with an "O" line cannot also carry standard-rated lines (EN 16931 rule BR-O-11), so mixed domestic and international jobs may need splitting. See [VAT category codes in Peppol](https://einvoices.uk/news/uk-vat-category-codes-peppol).

## Self-billing in haulage

Many hauliers and courier networks **self-bill** owner-drivers and subcontract hauliers. The customer calculates the amount from completed jobs and raises the VAT invoice for the supplier. [VAT Notice 700/62](https://www.gov.uk/guidance/self-billing-notice-70062) requires:

- a **written agreement** before self-billing starts, with start and end dates, in which the supplier agrees not to issue its own VAT invoices for the covered supplies
- each invoice marked **"SELF-BILLING"**, with full VAT invoice details. HMRC advises adding "The VAT shown is your output tax due to HMRC"
- no self-billed VAT invoices for suppliers who are **not VAT-registered**, or whose registration has been cancelled
- a **new agreement** if the supplier changes VAT number or transfers the business as a going concern
- corrections through **debit notes**, not by reducing a later invoice

Owner-drivers are often small businesses, and some are below the VAT threshold. Self-billers should check VAT status regularly. The "Check a VAT number" service is the simplest way.

### Self-billing over Peppol

Peppol publishes a **[BIS Self-Billing 3.0](https://docs.peppol.eu/poacc/self-billing/3.0/bis-sb/)** specification, in which the buyer sends the self-billed invoice to the seller. It uses invoice type code 389. The UK has not yet said how self-billing will work under the mandate. Open questions include whether self-billed suppliers will need their own Peppol connection to receive the invoices. See [self-billing and e-invoicing](https://einvoices.uk/news/self-billing-e-invoicing-uk).

## Fuel, tolls and customs disbursements

- **Fuel invoices.** Notice 700 (17.1) lets fuel sellers show the **vehicle registration number** instead of the customer's name and address on invoices over £250. Whether this concession carries over to e-invoices is not confirmed. Fleet card invoices from fuel card providers are a separate B2B flow.
- **Customs duty paid for a customer.** Notice 744B says these disbursements are outside the scope of VAT and "should normally be identified separately on your invoice". Your own costs, such as postage and phone, are part of your charge. Mixing out-of-scope disbursements with standard-rated freight raises the same coding question that law firms face. See [disbursements on e-invoices](https://einvoices.uk/news/e-invoicing-professional-services-law-firms).
- **Surcharges** (fuel surcharges, waiting time, failed delivery charges) are generally part of the consideration for your main supply and follow its VAT treatment. Check HMRC guidance if you are unsure. Put them as separate lines or charges with the right VAT category.

## Northern Ireland and cross-border flows

Haulage between Great Britain, Northern Ireland and the EU involves extra paperwork, and Northern Ireland businesses moving goods may use XI VAT numbers. Structured invoices will expose any mismatch between the customer's VAT identity and the movement. See [Northern Ireland and XI VAT](https://einvoices.uk/news/e-invoicing-northern-ireland-xi-vat) and [invoicing EU customers](https://einvoices.uk/news/uk-businesses-selling-to-eu-e-invoicing).

## Proof of delivery and attachments

Customers often hold invoices until they see proof of delivery (POD) or CMR notes. Peppol invoices can carry attachments and references to delivery documents, which can cut disputes. Agree with major customers which reference they match on. See [invoice attachments in Peppol](https://einvoices.uk/news/invoice-attachments-peppol).

## What is confirmed

- E-invoices for B2B and B2G VAT invoices from **April 2029**
- The government has [announced](https://www.gov.uk/government/publications/summary-of-tax-update-2026-simplification-modernisation-and-fairness/tax-update-2026-simplification-modernisation-and-fairness-summary) that Peppol will be the core interoperability network
- No real-time reporting at launch
- A roadmap due at Budget 2026 on 28 October 2026

## What to do now

1. **Split your invoices** into domestic, zero-rated import/export, out-of-scope and B2C. Count each group.
2. **Review self-billing agreements** with every subcontractor, and confirm their VAT status.
3. **Check that your transport management system** can produce structured invoices with correct VAT categories, or feeds an accounting system that can. See [check your software](https://einvoices.uk/news/check-accounting-software-peppol-support).
4. **Clean customer master data**, including VAT numbers, legal entities and the references each customer matches on. See [master data cleanup](https://einvoices.uk/news/master-data-cleanup-e-invoicing).

This is general information, not tax advice. See also the [mandate guide](https://einvoices.uk/mandate) and the [timeline](https://einvoices.uk/timeline).

## Frequently asked questions

### Do hauliers need e-invoicing from 2029?

VAT-registered hauliers issuing VAT invoices to VAT-registered customers or public bodies will need to send them as e-invoices from April 2029. Treatment of zero-rated international freight and of supplies outside the scope of UK VAT has not been confirmed.

### Is international haulage zero-rated?

Freight transport of goods being imported into or exported from the UK can be zero-rated where the place of supply is the UK, provided you hold commercial evidence linking your service to the import or export. B2B freight for a customer belonging outside the UK is generally outside the scope of UK VAT.

### Can I self-bill owner-drivers and subcontract hauliers?

Yes, under a written self-billing agreement that meets HMRC's conditions in VAT Notice 700/62. Each invoice must be marked 'SELF-BILLING'. Peppol has a self-billing specification, but the UK rules for self-billing under the mandate have not been published.

### Should customs duty paid for a customer carry VAT on my invoice?

HMRC's freight guidance says disbursements such as customs duty paid on a customer's behalf are outside the scope of VAT and should normally be shown separately on your invoice. Your own costs, such as postage and phone, form part of your charge.

---

How to cite: "Haulage e-invoicing: freight, self-billing and the 2029 mandate", einvoices.uk, 20 October 2026, https://einvoices.uk/news/e-invoicing-logistics-haulage

einvoices.uk is an independent publication and is not affiliated with HMRC or the UK Government. Nothing here is tax advice; check the sources and official GOV.UK guidance before acting.