Public Procurement (Electronic Invoices etc.) Regulations 2019

The Public Procurement (Electronic Invoices etc.) Regulations 2019 (SI 2019/624) required UK public bodies to accept and process e-invoices that meet the European e-invoicing standard, EN 16931. They gave suppliers a right to e-invoice, but did not oblige suppliers to do so. The 2029 mandate reverses that: the supplier will have to send.

This explainer covers what the regulations did, how Scotland differs, what replaced them under the Procurement Act 2023, and where the 2029 mandate fits in.

What the 2019 regulations did

The instrument was made on 20 March 2019 by the Minister for the Cabinet Office. It implemented the EU directive on e-invoicing in public procurement (Directive 2014/55/EU). It inserted a new e-invoicing rule into four sets of procurement regulations:

Regulations amended	New provision	In force
Public Contracts Regulations 2015	Regs 113A and 113B	18 April 2019 (sub-central authorities: 18 April 2020)
Utilities Contracts Regulations 2016	Reg A120	18 April 2020
Concession Contracts Regulations 2016	Regs 64A and 64B	18 April 2019 (utilities and sub-central: 18 April 2020)
Defence and Security Public Contracts Regulations 2011	Regs A66 and B66	18 April 2019 (utilities and sub-central: 18 April 2020)

The core rule, in regulation 113A of the Public Contracts Regulations 2015, worked like this:

• Every public contract awarded under Part 2 had to include a provision requiring the authority to accept and process an e-invoice submitted by or for the contractor.
• The conditions were that the invoice is undisputed and complies with the standard on electronic invoicing: the European standard plus one of the syntaxes listed in Commission Implementing Decision (EU) 2017/1870. In practice those syntaxes are UBL and UN/CEFACT CII. See UBL vs CII.
• If a contract left the term out, it was implied anyway.
• An "electronic invoice" meant one "issued, transmitted and received in a structured electronic format which allows for its automatic and electronic processing". A PDF does not meet that test. See does a PDF count as an e-invoice?

Exceptions and phasing

• Sub-central authorities (local authorities and similar bodies) got an extra year, to 18 April 2020, unless they were acting as a central purchasing body.
• Defence and security contracts were exempt if the contract was classified secret or needed special security measures, and the UK's essential security interests could not be protected if e-invoices had to be accepted.

Wales and Northern Ireland

The 2019 instrument amended regulation 1 of the Public Contracts Regulations 2015 so that regulations 113A, 113B and 114 apply to contracting authorities with wholly or mainly Welsh or Northern Ireland devolved functions. Welsh and Northern Ireland public bodies were therefore covered by the same rule.

Scotland had its own regulations

Scotland transposed the directive separately. The Electronic Invoicing (Public Contracts etc.) Amendment (Scotland) Regulations 2019 (SSI 2019/7) inserted:

• regulation 70A into the Public Contracts (Scotland) Regulations 2015
• regulation 44A into the Concession Contracts (Scotland) Regulations 2016
• regulation 84A into the Utilities Contracts (Scotland) Regulations 2016

These came into force on 18 April 2019 for central government authorities and all NHS Scotland bodies, and on 18 April 2020 for everyone else. The Scottish version goes further than the UK text: it lists the "information components" a compliant e-invoice must contain. These include process and invoice identifiers, seller, buyer and payee details, contract reference, delivery details, payment instructions, line items, totals and VAT breakdown. That list mirrors the core of EN 16931.

Regulation 70A remains in force. The Procurement Act 2023 excludes "devolved Scottish authorities" (section 2(5)), so Scottish public bodies still work under the Scottish regulations.

What replaced the 2019 regulations

legislation.gov.uk now lists SI 2019/624 as revoked. For England, Wales and Northern Ireland, the rule now sits in section 67 of the Procurement Act 2023, in force from 24 February 2025:

• Every public contract carries an implied term that the authority must accept and process for payment any e-invoice that is in the "required electronic form" and not disputed.
• The "required electronic form" is defined by reference to BS EN 16931-1:2017 and the syntax list in PD CEN/TS 16931-2:2017. Those are the British Standards Institution editions of the same European documents.
• Any term trying to restrict or override this is of no effect.
• The authority may require a particular system for e-invoices. Only defence authorities may require a system that charges suppliers fees.
• Ministers can change the meaning of "required electronic form" by regulations (s.67(7)), after consultation.

Cabinet Office guidance on e-invoicing and payment describes this as carrying forward the effect of the 2019 amendments. It also notes that suppliers "will always have the right to submit an electronic invoice". Contracts procured under the old regulations generally keep the old rules for their lifetime.

The Act also implies 30-day payment terms (section 68). An invoice counts as valid for those terms if it is a compliant e-invoice, or if it carries the minimum information and meets the contract's requirements. The e-invoicing term in section 67 applies to "public contracts", meaning those procured under the Act. Regulated below-threshold contracts get the 30-day payment term (section 88), but there is no equivalent e-invoicing term.

How this fits with the 2029 mandate

	2019 regulations / Procurement Act s.67	2029 mandate
Obligation falls on	The public buyer, to accept	The supplier, to issue VAT invoices as e-invoices
Scope	Public contracts under the procurement rules	VAT invoices, B2B and B2G
Standard	EN 16931 + listed syntax	Peppol confirmed as network; detailed data standard not yet published
Network	Not specified	Peppol
Source of rule	Procurement law	VAT and e-invoicing law (still to be made)

Confirmed: from April 2029, VAT invoices to public-sector bodies must be e-invoices; the government has announced that Peppol will be the core interoperability network; there will be no real-time reporting at launch.

Not yet confirmed:

• Whether section 67's "required electronic form" will be amended to match the national standard, for example a UK Peppol specification
• How public bodies' current portals, which section 67 allows, will sit alongside a Peppol-based mandate
• Whether Scotland will amend regulation 70A to match, since procurement is devolved but VAT is not
• How invoices that are not VAT invoices will be treated, such as those from suppliers who are not VAT-registered

These are among the questions we expect the Budget 2026 roadmap to start answering on 28 October 2026.

For how section 67 of the Procurement Act 2023 works from the supplier's side, and why it obliges public buyers to accept e-invoices rather than obliging suppliers to send them, see Procurement Act 2023 and e-invoicing: section 67 explained.

What to do now

• Suppliers: you already have a legal right to send compliant e-invoices to public buyers. Using it now, ideally over Peppol, is good practice for 2029. Start with the guides for councils, central government and the NHS.
• Public bodies: check that your accounts payable system can receive and process EN 16931 invoices, not just PDFs, and that your contracts don't purport to restrict the implied term.

See also the mandate guide and EN 16931 explained.