VAT Notice 700/63 explained: HMRC's e-invoicing rules today

VAT Notice 700/63 is HMRC's guidance on sending, receiving and storing VAT invoices electronically. It says an electronic invoice can be your VAT invoice if your customer agrees and you can guarantee the invoice's "authenticity of the origin, integrity of invoice data, and legibility". It accepts PDFs as well as structured formats such as XML, and it is the rulebook that applies today, until the 2029 mandate takes over.

The notice was first published on 19 May 2015 and last updated on 26 May 2022. Below is a plain summary of each section, then a comparison with what the 2029 mandate is expected to change.

Section 2: what counts as electronic invoicing

• 2.1 Definition. "Electronic invoicing is the transmission and storage of invoices in an electronic format without duplicate paper documents. The electronic format may be a structured format such as XML or an unstructured format such as PDF."
• 2.3 Choice. "It's up to you whether you issue paper or electronic VAT invoices."
• 2.4 No dual running. Issuing electronic and paper invoices for the same supplies, or to the same customers, is a "dual system". You may only do it during a "controlled trial" of an electronic invoicing system. After the trial, "the electronic invoice then becomes the legal document for VAT purposes." If you have a specific business need, you can ask VAT general enquiries for an exception.
• 2.5 No notification. You do not need to tell HMRC you are invoicing electronically, but you must be satisfied that your system complies. HMRC's internal manual (VATREC7090) confirms there is "no longer any requirement" for approval.

Section 3: what an electronic invoice must contain

Electronic invoices "must contain the same information as paper invoices". The notice lists the standard VAT invoice particulars: an identifying number, the time of supply, the date of issue, your name, address and VAT number, your customer's name and address, a description, unit price, quantity, VAT rate, the amount payable excluding VAT, any cash discount rate and the total VAT.

Some practical extras:

• 3.3 Batches. Details common to a batch of invoices to the same customer can be recorded once per file, in a batch header.
• 3.4 Credit notes must contain the same details as the original invoice and enough to identify it. See credit notes on Peppol.
• 3.5 Currency. Amounts can be in any currency, but total VAT must be shown in sterling where UK VAT is due. See multi-currency e-invoices.

For the full UK list, see our guide to VAT invoice requirements, or test an invoice with our VAT invoice checker.

Section 4: conditions for sending

This is the heart of the notice. Paragraph 4.1 says you may invoice electronically where "the authenticity of the origin, integrity of invoice data, and legibility can all be ensured, and your customer agrees to receive invoices electronically".

Term	HMRC's meaning
Authenticity of the origin	"the assurance of the identity of the supplier or issuer of the invoice"
Integrity of content	"the invoice content has not been altered"
Legibility	"the invoice can be easily read"

You choose how to meet these. HMRC gives three examples:

1. An advanced or qualified electronic signature (4.2).
2. EDI (4.3), with an interchange agreement between trading partners covering secure networks, messaging protocols such as AS2 and syntax checks. See e-invoicing vs EDI.
3. Reliable business controls (4.4) that create an audit trail between the invoice and the supply, for example matching invoices to orders and delivery notes, and separating who maintains supplier data from who enters invoices.

Paragraph 4.5 also accepts other means, such as network security, access controls and "message transfer protocols (for example, https)", as long as you can show "a satisfactory level of control".

Other rules in this section:

• 4.7 Formats. HMRC accepts "a wide variety" of formats, including UN/EDIFACT, EANCOM, ODETTE, XML-based standards, "comma-delimited ASCII, PDF".
• 4.8 Secure transmission using industry-accepted technologies on the message or the link, such as https, SSL or S/MIME, or "other procedural means which offer similar assurances".
• 4.10 Internal controls. You must be able to show control over completeness and accuracy, timeliness, corruption in transit and duplicate processing, and have a recovery plan for system failure.
• 4.11 to 4.13 Cross-border. Invoices to EU customers must meet UK conditions, show your number with the GB prefix and the customer's VAT number with its country code. For non-EU countries, check with that country's tax authority first.

Section 5: conditions for storing

Paragraph 5.2 says you must guarantee authenticity and integrity "throughout the storage period", store all data related to your invoices, "be able to recreate the invoice data as at the time of its original transmission or receipt" and keep history files.

• 5.3 Scanned paper invoices can be stored electronically if authenticity, integrity and legibility are kept during conversion.
• 5.4 Keep invoices issued and received for 6 years normally. HMRC may agree a shorter period if storage causes serious problems.
• 5.5 and 5.6 Storage abroad is allowed if you can produce records in a readable form within a reasonable time, and data protection principles are respected.

Our archiving and retention guide covers this in more depth.

Sections 6 to 9: access, receiving, outsourcing and failure

• 6.1 HMRC access. HMRC may ask for access to the systems that produce or receive invoices, their documentation and audit trail, and must be able to take copies.
• 7.2 Receiving. If you do not want electronic invoices, ask suppliers for paper. "This is a commercial matter between you and your supplier." See can a customer refuse an e-invoice?.
• 7.3 Foreign suppliers. Invoices from abroad follow the supplier's country's rules but must contain enough to calculate import VAT or reverse-charge output tax.
• 8.1 Self-billing. Self-billing systems must recognise self-billed invoices so input and output tax are accounted for correctly. See self-billing and e-invoicing.
• 8.2 Outsourcing. If a third party issues your invoices, "all the legal obligations ... remain with you". This matters when choosing an Access Point.
• 9.1 and 9.2 Failure. If you cannot meet the conditions, issue paper. If you persistently fail to meet them, "you may be liable to a penalty".

Notice 700/63 today vs the 2029 mandate

Topic	Notice 700/63 today	2029 mandate
Is PDF an electronic invoice?	Yes	No: the consultation said PDF and Word invoices are not e-invoices (confirmed policy)
Is electronic invoicing optional?	Yes, "up to you"	No for VAT invoices: "issued in a specified electronic format from April 2029" (confirmed)
Customer agreement	Required (regulation 13A)	Change to the consent rule not yet confirmed
Network	Any secure method: email, EDI, https	Peppol is "the core interoperability network" (confirmed, June 2026); role of legacy systems still under discussion
Data standard	Any format with the required data	Not yet confirmed: the government is reviewing an existing standard versus a UK-specific one
Storage	6 years, authenticity and integrity kept	Not yet confirmed whether rules change
Reporting to HMRC	None	None at launch: no real-time reporting in 2029 (confirmed)

The biggest difference is the definition. The notice's "electronic invoice" is any invoice sent and stored without paper. The mandate's "e-invoice" is structured data exchanged between systems. Read more in does a PDF invoice count as an e-invoice?.

HMRC has not announced a rewrite of Notice 700/63. Since its definition and its customer-consent rule do not fit a mandate, an update is likely at some point. The implementation roadmap is due at Budget 2026 on 28 October 2026, and we will update this page when the notice changes.

What to do now

1. Check you meet the notice today if you email invoices: customer agreement, a reliable audit trail, secure sending and 6-year storage.
2. Stop any accidental dual running, such as posting paper copies of emailed invoices as standard.
3. Write down your controls. A one-page note of how you ensure authenticity and integrity is useful evidence.
4. Plan for structured invoices using our readiness checklist and the mandate guide.