# Invoicing a council electronically: a supplier's guide > Councils must accept compliant e-invoices on above-threshold contracts. Here is what that means today, how it differs across the UK, and what April 2029 adds. - Canonical URL: https://einvoices.uk/news/local-council-e-invoicing-suppliers - 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: Public sector, 2029 mandate, Small business, Peppol - Language: en-GB (UK English); covers the United Kingdom ## Sources - [Procurement Act 2023, section 67: Electronic invoicing: implied term](https://www.legislation.gov.uk/ukpga/2023/54/section/67) - [Procurement Act 2023, section 88: Regulated below-threshold contracts: implied payment terms](https://www.legislation.gov.uk/ukpga/2023/54/section/88) - [Guidance: Electronic Invoicing and Payment (HTML)](https://www.gov.uk/government/publications/procurement-act-2023-guidance-documents-manage-phase/guidance-electronic-invoicing-and-payment-html) - [The Public Contracts (Scotland) Regulations 2015, regulation 70A](https://www.legislation.gov.uk/ssi/2015/446/regulation/70A) - [VAT guide (VAT Notice 700)](https://www.gov.uk/guidance/vat-guide-notice-700) - [What you must do as a Construction Industry Scheme (CIS) contractor](https://www.gov.uk/what-you-must-do-as-a-cis-contractor) --- You can already invoice most councils electronically. On contracts procured under the **Procurement Act 2023**, a council must accept and process an undisputed e-invoice that meets the EN 16931 standard. From **April 2029**, sending VAT invoices to public bodies as e-invoices stops being optional: it becomes a legal requirement for the supplier. Here is how council invoicing works now, where the rules differ across the UK, and what to prepare for. ## The rule today: councils must accept compliant e-invoices Councils are "sub-central" contracting authorities. They came under the e-invoicing rule on **18 April 2020**, a year after central government, under the Public Contracts Regulations 2015 as amended in 2019. For procurements under the Procurement Act 2023, from 24 February 2025, [section 67](https://www.legislation.gov.uk/ukpga/2023/54/section/67) applies: - Every **public contract** carries an implied term that the council must accept and process for payment an e-invoice that is in the "required electronic form" and not disputed. - "Required electronic form" means compliant with **BS EN 16931-1:2017** and using a syntax listed in **PD CEN/TS 16931-2:2017**. In practice that means UBL or CII, which is what Peppol BIS Billing 3.0 uses. - The council **can require a particular system**. Many councils route suppliers through a supplier portal or an e-invoicing provider, or name an inbox for invoices. - Any contract term that tries to restrict this right is of no effect. Two practical consequences. First, an emailed PDF is not an "electronic invoice" in this sense. It is an ordinary invoice that happens to arrive electronically. Second, the right covers **public contracts**. Cabinet Office [guidance](https://www.gov.uk/government/publications/procurement-act-2023-guidance-documents-manage-phase/guidance-electronic-invoicing-and-payment-html) notes that e-invoicing was not mandated for below-threshold contracts under the old regime. The Act's term for regulated below-threshold contracts ([section 88](https://www.legislation.gov.uk/ukpga/2023/54/section/88)) covers payment, not e-invoicing. ## Payment: 30 days from receipt Councils must pay within **30 days** of receiving an invoice, or by the due date on the invoice if that is later. This is implied by section 68 for public contracts and section 88 for regulated below-threshold contracts. If the council thinks your invoice is invalid or disputes it, it must tell you **without undue delay**. An invoice is valid for these purposes if it is a compliant e-invoice, or if it carries the minimum information and meets the contract's requirements. The minimum is your name, a description of what you supplied, the sum requested and a unique identification number. (Below-threshold contracts use only the minimum-information test.) Where the council uses an e-invoicing system, the guidance says the day your invoice lands on that system counts as the day of receipt. A structured e-invoice gives you a clear timestamp, which a PDF lost in a shared inbox does not. The payment terms are **not** implied into contracts awarded by a **school**, into concession contracts, or into utilities contracts let by private utilities. ## What a council invoice needs Most rejected council invoices fail on references rather than VAT. Before sending, check: - **Purchase order number.** Many councils operate "no PO, no pay". Put it exactly where the buyer expects it. In Peppol that is usually the order reference or the buyer reference. See [buyer reference and PO reference](https://einvoices.uk/news/purchase-order-reference-buyer-reference-peppol). - **The right legal entity.** Councils often have several invoicing entities (for example a council and its pension fund or trading company). Use the one named on the order. - **VAT treatment.** Councils are charged VAT in the usual way. [VAT Notice 700](https://www.gov.uk/guidance/vat-guide-notice-700) (paragraph 8.15) says suppliers to local authorities should "charge and account for VAT in the usual way". Councils have their own mechanism for recovering it. Do not zero-rate a supply just because the customer is a council. - **Full VAT invoice details.** See [what a VAT invoice must include](https://einvoices.uk/news/uk-vat-invoice-requirements-e-invoicing). ### Construction work for councils A local authority that spends more than £3 million on construction in 12 months becomes a **deemed contractor** under the Construction Industry Scheme. Construction subcontractors to councils may therefore see CIS deductions and the VAT domestic reverse charge. See [construction e-invoicing and CIS](https://einvoices.uk/news/e-invoicing-construction-cis). ## England, Scotland, Wales and Northern Ireland | Nation | Rule for councils | Since | |---|---|---| | England | Procurement Act 2023 s.67 (older contracts: PCR 2015 reg 113A) | 18 April 2020 (s.67 for procurements from 24 Feb 2025) | | Wales | Procurement Act 2023 s.67; Welsh Government publishes parallel guidance | As England | | Northern Ireland | Procurement Act 2023 s.67 (older contracts: PCR 2015 reg 113A) | As England | | Scotland | Public Contracts (Scotland) Regulations 2015, reg 70A, an implied term to accept compliant e-invoices | 18 April 2020 | The Procurement Act does not apply to devolved Scottish authorities, so Scottish councils stay under the Scottish regulations. The practical effect for suppliers is the same: a compliant, undisputed e-invoice must be accepted. The 2029 VAT mandate will apply across the whole UK, because VAT is not devolved. ## What changes in April 2029 **Confirmed:** - VAT invoices issued by businesses to public-sector bodies (B2G) must be e-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. - The model is decentralised, with no real-time reporting to HMRC at launch. **Not yet confirmed:** - Whether councils will have to retire supplier portals in favour of Peppol, or whether portals will connect to Peppol behind the scenes - How the procurement-law definition of "required electronic form" will line up with the national standard - How invoices from suppliers who are not VAT-registered will be treated (many small council suppliers fall below the £90,000 threshold). See [e-invoicing for non-VAT-registered businesses](https://einvoices.uk/news/e-invoicing-non-vat-registered-businesses) - How invoices that councils themselves issue to businesses will be handled, for example commercial waste or room hire. The mandate covers VAT invoices generally, but there is no detailed guidance for public bodies as sellers yet ## What to do now 1. **Ask each council customer** how it wants invoices today: Peppol, portal or email. Record its PO rules. 2. **Move to structured e-invoices where you can.** You already have the legal right on public contracts, and it builds the habit before 2029. 3. **Check whether your accounting software can send over Peppol.** See [checking your software's Peppol support](https://einvoices.uk/news/check-accounting-software-peppol-support). 4. **Use our [scope checker](https://einvoices.uk/tools/am-i-in-scope)** to see where the mandate is likely to bite for you. Related: [central government invoicing](https://einvoices.uk/news/central-government-e-invoicing-suppliers), [the 2019 regulations explained](https://einvoices.uk/news/public-sector-e-invoicing-regulations-2019) and the [timeline](https://einvoices.uk/timeline). ## Frequently asked questions ### Does a council have to accept an electronic invoice? On public contracts procured under the Procurement Act 2023, yes. The council must accept and process an undisputed e-invoice that meets the EN 16931 standard. It can require you to use a particular system to send it. Below-threshold contracts carry no equivalent e-invoicing term. ### Is a PDF emailed to a council an e-invoice? Not in the legal sense. The Procurement Act defines an e-invoice as one in a structured format that allows automatic processing. A PDF is an electronic document, but it is not structured data. ### How quickly must a council pay my invoice? Within 30 days of receiving it, under terms implied by the Procurement Act 2023, unless it considers the invoice invalid or disputes it. It must then tell you without undue delay. A contract can set a shorter period, but not a longer one. ### Will councils need Peppol from 2029? VAT invoices to public bodies must be e-invoices from April 2029, and Peppol is the confirmed network, so councils will need to be able to receive over it. Exact requirements for public-sector buyers have not yet been published. --- How to cite: "Invoicing a council electronically: a supplier's guide", einvoices.uk, 20 October 2026, https://einvoices.uk/news/local-council-e-invoicing-suppliers 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.