# Self-billing and e-invoicing: what HMRC rules mean for 2029 > Self-billing will survive e-invoicing: Peppol has a self-billing standard and HMRC's Notice 700/62 still applies. Here's what is confirmed and what is open. - Canonical URL: https://einvoices.uk/news/self-billing-e-invoicing-uk - 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: VAT, Peppol, Technical, Compliance - Language: en-GB (UK English); covers the United Kingdom ## Sources - [Self-billing (VAT Notice 700/62)](https://www.gov.uk/guidance/self-billing-notice-70062) - [Electronic invoicing (VAT Notice 700/63)](https://www.gov.uk/guidance/electronic-invoicing-notice-70063) - [Peppol BIS Self-Billing 3.0](https://docs.peppol.eu/poacc/self-billing/3.0/bis-sb/) - [Promoting electronic invoicing across UK businesses and the public sector: consultation response](https://www.gov.uk/government/consultations/promoting-electronic-invoicing-across-uk-businesses-and-the-public-sector/outcome/promoting-electronic-invoicing-across-uk-businesses-and-the-public-sector-consultation-response) - [VAT guide (VAT Notice 700)](https://www.gov.uk/guidance/vat-guide-notice-700) --- **Self-billing is expected to continue under UK e-invoicing, but the UK-specific rules are not yet published.** HMRC's self-billing rules in [VAT Notice 700/62](https://www.gov.uk/guidance/self-billing-notice-70062) still apply. The UK has chosen Peppol, which already has a dedicated self-billing standard. And the government's consultation response says HMRC has confirmed that concerns "including self-billing and the VAT reverse charge" have been addressed in other jurisdictions' mandates. What is not confirmed is exactly how a self-billed e-invoice will be specified and validated in the UK from April 2029. ## A quick recap of self-billing Self-billing is "a commercial arrangement between a supplier and a customer in which the customer prepares the supplier's invoice and forwards a copy to the supplier with the payment." It is common where the customer decides the value, such as: - agricultural produce and livestock - scrap metal and recycling - royalties and commissions - haulage and courier sub-contracting - construction sub-contracting You do not need HMRC's permission to self-bill. You do need to follow the rules. ## The HMRC rules that still apply Under Notice 700/62 (law: VAT Act 1994 section 29 and VAT Regulations 1995 regulation 13(3) to 13(3F)): - **A written agreement must be in place before self-billing starts.** It must include the supplier's agreement to accept self-billed invoices, a promise not to issue its own VAT invoices for the same supplies, a start and expiry date, and a commitment to tell you about VAT registration changes. It must also say if a third party will issue the self-bills. - **Each self-billed invoice must be marked "SELF-BILLING".** This sentence in the notice has the force of law. HMRC also advises adding: "The VAT shown is your output tax due to HMRC". - **The invoice must contain all the normal VAT invoice details.** - **You must not self-bill unregistered suppliers**, or a supplier whose VAT number has changed until a new agreement is in place. - **Corrections** use a debit note rather than reducing a later invoice. - **Breaking the rules** means the documents are not proper VAT invoices, so they cannot support your input tax claim. HMRC suggests reviewing agreements every 12 months. Notice 700/63 adds that any electronic self-billing system must recognise self-billed invoices so that input and output tax are accounted for correctly. ## How self-billing works in Peppol The UK will use [Peppol](https://einvoices.uk/news/what-is-peppol). Peppol publishes a separate specification, **Peppol BIS Self-Billing 3.0**, alongside the standard billing specification. Its key features: | Element | Self-billing value | |---|---| | Specification identifier (CustomizationID) | `urn:cen.eu:en16931:2017#compliant#urn:fdc:peppol.eu:2017:poacc:selfbilling:3.0` | | Business process (ProfileID) | `urn:fdc:peppol.eu:2017:poacc:selfbilling:01:1.0` | | Self-billed invoice type code | 389 ("an invoice the invoicee is producing instead of the seller") | | Self-billed credit note type code | 261 | | Who sends | The buyer, to the seller | The direction of travel is reversed. In normal Peppol billing, the supplier sends an invoice to the buyer. In self-billing, the **buyer** sends the self-billed invoice to the **seller's** Peppol ID. So: - the **supplier** must be registered on Peppol to *receive* self-billing documents, which is a separate document type from ordinary invoices - the **customer** must be able to *send* them - both sides' software must treat the VAT on the document correctly: output tax for the supplier, input tax for the customer These identifiers come from the current Peppol specification (May 2026 release). Whether the UK will adopt Peppol BIS Self-Billing as-is, or with UK-specific rules, is **not confirmed**. ## Questions the roadmap needs to answer - Will self-billed invoices be in scope from April 2029 on the same date as other VAT invoices? - Will the "SELF-BILLING" marking be satisfied by the document type code, or must it appear as text? - What happens if the supplier is not on Peppol? Under the current rules, the supplier would have to issue its own invoices. That would undo the arrangement. - How will the 14-day tax point rule and notional tax point apply to e-invoices? - How will third-party bureaux that issue self-bills be treated? ## Tax points still matter Issuing a self-billed invoice does not normally create a tax point. The exception is when you issue it within 14 days of the basic tax point. The self-biller can use a notional tax point of the day after issue when it pays with the self-bill. Nothing announced changes those rules. Make sure your e-invoicing system records the correct tax point date on each document. ## What to do now 1. **List every self-billing arrangement**, with the supplier's VAT number and agreement expiry date. 2. **Check agreements are current and in writing.** Agreements have expiry dates and can lapse unnoticed. 3. **Ask your ERP or AP provider** whether it supports Peppol BIS Self-Billing, both sending and receiving. 4. **Contact your self-billed suppliers** early. They will need to be reachable on Peppol for self-billing documents. 5. **Keep reconciliations tight.** Duplicate invoices, one self-billed and one from the supplier, are a common error that HMRC specifically warns about. See our glossary entry on [self-billing](https://einvoices.uk/news/self-billing-e-invoicing-uk), and check [who is in scope](https://einvoices.uk/news/who-is-in-scope-uk-e-invoicing-mandate) for the wider picture. ## Frequently asked questions ### Is self-billing allowed under UK e-invoicing? Nothing announced removes it. Self-billing is still governed by VAT Notice 700/62, and HMRC noted in the consultation response that other countries' mandates have addressed self-billing. The UK-specific rules have not yet been published. ### Who sends the e-invoice in a self-billing arrangement? The customer (self-biller) creates the invoice on the supplier's behalf. In Peppol this uses a dedicated self-billing specification, with invoice type code 389. ### Do I still need a self-billing agreement? Yes. HMRC's rules require a written agreement in place before self-billing starts, with a start and expiry date. E-invoicing does not change that. ### Does a self-billed e-invoice still need to say 'SELF-BILLING'? Under current rules each self-billed invoice must be marked 'SELF-BILLING', and that requirement has the force of law. How the UK e-invoice specification will carry that marking has not been confirmed. --- How to cite: "Self-billing and e-invoicing: what HMRC rules mean for 2029", einvoices.uk, 20 October 2026, https://einvoices.uk/news/self-billing-e-invoicing-uk 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.