Can you reclaim VAT without an e-invoice after 2029?

Today, you reclaim input VAT by holding a valid VAT invoice from your supplier, and HMRC can accept other evidence only in exceptional cases. From April 2029 suppliers must issue VAT invoices in a specified electronic format. Whether a supplier's failure to do that will stop you, the buyer, from reclaiming the VAT has not been confirmed. The consultation response does not mention input tax recovery at all.

That gap matters to accounts payable teams. Here is the current law, what is and is not known about 2029, and how to protect your claims in the meantime.

The rule today: hold the invoice

Regulation 29 of the VAT Regulations 1995 sets the evidence rule. When you claim input tax on a supply from another taxable person, you must "hold the document which is required to be provided under regulation 13", which is the VAT invoice.

HMRC's manual (VIT31000) lists what counts as evidence:

• a VAT invoice meeting regulation 14
• a self-billed invoice under a valid arrangement
• a "less detailed" invoice where the VAT-inclusive value is £250 or less
• an authenticated receipt for construction stage payments

The timing follows the invoice. Under regulation 29(1), if you do not hold the invoice when the VAT becomes chargeable, you claim on the return for "the first prescribed accounting period in which he holds that document or invoice". There is also an outer limit: HMRC cannot allow a claim more than 4 years after the due date of the return for the first period in which you could have claimed.

Where electronic invoices fit in

An emailed or uploaded invoice can be the VAT invoice today, PDFs included. But regulation 13A(2) adds a condition: an electronic document "is not to be treated as the VAT invoice ... unless the use of the electronic invoice is accepted by the customer". In practice, if you accept invoices from a supplier by email, the PDF is your evidence. See can a customer refuse an e-invoice? and VAT Notice 700/63 explained.

HMRC's discretion: the safety net, not a plan

Regulation 29(2) lets HMRC direct that "such other ... evidence of the charge to VAT" is acceptable. HMRC's manual VIT31200 explains how staff use this:

• HMRC "will not simply refuse a claim without giving reasonable consideration" to alternative evidence.
• If you do not hold an invoice, you "must go back to the supplier and request one". HMRC may consider alternative evidence "where the taxpayer can demonstrate attempts made to obtain a VAT invoice without success".
• Alternative evidence "is allowed only in exceptional circumstances", and where a business uses it "as a routine, HMRC can refuse to exercise discretion".
• Where satisfactory evidence exists and there is no suspicion of fraud, staff "should normally exercise their discretion" to allow the claim.

The questions HMRC staff may ask include whether you have a supplier statement, evidence of receipt, evidence of payment and how you know the supplier is genuine. Keep those records for any invoice you are unsure about.

What 2029 changes, and what it might not

Question	Status
Must suppliers issue VAT invoices in a specified electronic format from April 2029?	Confirmed (Budget 2025)
Is a PDF an e-invoice for the mandate?	No (confirmed policy: the consultation says PDF and Word invoices are not e-invoices)
Will a PDF from a non-compliant supplier still be a valid VAT invoice for your claim?	Not yet confirmed
Will HMRC's regulation 29 discretion cover non-compliant invoices?	Not yet confirmed
Will buyers be penalised for accepting non-compliant invoices?	Not yet confirmed. See e-invoicing penalties
Transitional period or soft landing?	Not yet confirmed

There are two broad ways the rules could go. The law could make the e-invoice the VAT invoice, so that a PDF no longer satisfies regulation 29 and only HMRC's discretion would help. Or it could put the duty on the supplier, with penalties for the supplier, and leave the buyer's evidence rule largely alone. The government has not said which approach it will take.

The implementation roadmap is due at Budget 2026 on 28 October 2026. It may answer this; if it does not, the draft legislation will. We will update this page.

How to protect your input VAT now

Whatever the final rule, the risk concentrates on a small number of suppliers. These steps help in both scenarios.

1. Know your suppliers' formats. Record whether each supplier sends paper, PDF, EDI, portal or Peppol invoices. Our Peppol Directory lookup shows who is already registered.
2. Put e-invoicing in supplier onboarding. Ask for Peppol capability on new supplier forms and in contract renewals. See supplier onboarding for e-invoicing.
3. Check invoices are complete. A PDF missing a VAT number or VAT amount is already a problem today. Our VAT invoice checker tests the required details.
4. Chase missing invoices in writing. HMRC's discretion depends on showing you asked. Keep the emails.
5. Keep supporting evidence: purchase orders, delivery notes, proof of payment.
6. Hold PDFs and data together for 6 years. See e-invoice archiving.
7. Plan an escalation route for suppliers who will not be ready by April 2029, once the rules are known.

For the wider AP picture, read accounts payable and e-invoicing.

What to do now

• Do not change how you claim today. Current rules apply until the mandate starts.
• Map supplier formats and identify the ones who still send paper or PDF.
• Read the roadmap on 28 October 2026 for anything on the buyer's position, and check our timeline.

This is general information, not tax advice. For a specific claim, see HMRC's guidance or ask an adviser.