NHS Peppol invoicing: what suppliers need to know

If you supply the NHS in England, you may be invoicing over Peppol already. NHS Supply Chain trades with its suppliers over the Peppol network, and many trusts adopted Peppol under the Department of Health's 2014 eProcurement Strategy. From April 2029, every VAT invoice to a public body will have to be an e-invoice. Peppol is confirmed as the UK's network, so NHS suppliers who are already connected start well ahead.

This guide sets out what is confirmed today, what the mandate adds, and what is still open.

Where NHS Peppol came from

The Department of Health published the NHS e-procurement strategy in May 2014. It set two standards for NHS procurement:

• GS1 for product data and location identifiers, such as Global Location Numbers (GLNs)
• Peppol for purchase orders, advance shipping notes and invoices

The strategy did not make this a tax rule. It applied through contracts. The 2014/15 NHS Standard Contract required providers to comply with the strategy, and acute NHS trusts (foundation and non-foundation) had to draw up and start a GS1 and Peppol adoption plan approved by their board. Suppliers were told to plan for receiving Peppol purchase orders and sending advance shipping notes and invoices. The model was four-corner: each trust and each supplier picks its own Access Point, and pays only its own provider.

Who runs Peppol for the NHS today

OpenPeppol's country profile for England NHS says:

• The formal Peppol Authority agreement is still between OpenPeppol and the Department of Health and Social Care (DHSC).
• Day-to-day operation of the Peppol Authority has passed to Supply Chain Coordination Ltd (SCCL), which owns and runs NHS Supply Chain.
• OpenPeppol, as Coordinating Authority, holds the agreements with Peppol service providers based in the UK.
• NHS Supply Chain sends purchase orders and receives despatch advice and invoices over Peppol, and says all its suppliers use Peppol to exchange documents with it.

That last point matters. If NHS Supply Chain is your customer, Peppol is already part of how you do business with it, whatever the 2029 rules turn out to be.

The legal floor: trusts must accept compliant e-invoices

Separately from NHS policy, public procurement law already gives you a right to e-invoice. Under section 67 of the Procurement Act 2023, every public contract carries an implied term that the contracting authority must accept and process an undisputed e-invoice in the "required electronic form". That means it complies with BS EN 16931-1:2017 and uses one of the listed syntaxes. Peppol BIS Billing 3.0 is built on EN 16931.

Two qualifications:

• The authority may require you to use a particular system for e-invoices (s.67(6)). A trust can tell you to send through Peppol or through its own portal.
• The Act applies to contracts awarded under it from 24 February 2025. Older contracts carry the equivalent term from the Public Contracts Regulations 2015. See our explainer on the 2019 e-invoicing regulations.

Scotland, Wales and Northern Ireland

The 2014 strategy applied to England. Elsewhere:

• Scotland. NHS Scotland bodies have been under Scottish law since 18 April 2019. The Electronic Invoicing (Public Contracts etc.) Amendment (Scotland) Regulations 2019 implied an e-invoice acceptance term into their public contracts from that date, a year before most other Scottish authorities. The Procurement Act 2023 does not apply to devolved Scottish authorities.
• Wales and Northern Ireland. Health bodies are covered by the Procurement Act 2023, including the section 67 term. NHS Peppol policy in these nations is not the same as England's, so check with each buyer what it expects.

What changes in April 2029

	Today	From April 2029
Legal basis	Contract terms (NHS Standard Contract, buyer requirements) and procurement law	Requirement to issue VAT invoices as e-invoices (B2G is in scope)
Who must act	The NHS buyer must accept a compliant e-invoice. The supplier chooses whether to send one, unless the contract says otherwise	The supplier must issue its VAT invoices as e-invoices
Network	Peppol is widely used, alongside portals and PDF	Peppol confirmed as the core interoperability network
Reporting to HMRC	None	None at launch: no real-time reporting

The government has announced that "the electronic procurement system Peppol will be the core interoperability network for e-invoicing in the UK". For an NHS supplier already on Peppol, that is the best possible outcome: the connection you have is the one the national regime will use.

What is not yet confirmed

• The UK data standard. Nobody yet knows whether the UK will use Peppol BIS Billing 3.0 unchanged or publish a UK CIUS with extra rules. NHS invoices that pass today's Peppol validation may need small changes.
• Identifiers. NHS e-procurement was built on GS1 GLNs. Peppol identifies GLNs with scheme 0088. The UK may standardise on another identifier, such as the VAT-number scheme 9932, or allow several. See Peppol EAS codes 9932 and 0088.
• Purchase orders and other documents. The mandate is about VAT invoices. Peppol orders, order responses and despatch advice stay NHS business requirements.
• Governance. It has not been said how NHS Peppol governance will fit with a national Peppol Authority for the mandate.

These are the kinds of details expected in the roadmap due at Budget 2026 on 28 October 2026.

Practical points for NHS suppliers

• Don't run two invoice copies. HMRC's Electronic invoicing notice (700/63) says that sending paper and electronic invoices for the same supplies is a "dual system", which is allowed only during a controlled trial. If you send over Peppol, stop also emailing a PDF copy as the invoice.
• Match the order. NHS buyers match invoices to Peppol purchase orders. Quote the order reference exactly, as many rejections come down to a missing or mistyped reference. See buyer reference and PO reference.
• Keep your GLNs and Peppol registration current. Check that your entry in the Peppol Directory is correct and points at the right Access Point.
• Read your Invoice Responses. If your Access Point supports it, a Peppol Invoice Response can tell you quickly whether a trust has accepted, queried or rejected an invoice.

What to do now

1. List your NHS customers and how each one wants to receive invoices today: Peppol, a portal or email.
2. If you are not on Peppol yet, talk to your accounting or ERP provider about connecting through an Access Point. You will need it for all your B2B and B2G customers by 2029 anyway. Our guide to choosing an Access Point explains what to ask.
3. Watch for the roadmap on 28 October 2026. Then compare its data requirements with what your NHS invoices already carry.

For the wider picture, see the mandate guide, the timeline and What is Peppol?.