E-Invoicing in United Kingdom

Country Situation

General Description

The UK has introduced sector-specific B2G e-invoicing obligations under the NHS e-procurement strategy.

Published in 2014, the strategy aims to modernise procurement, improve efficiency, and enhance patient safety by mandating the use of GS1 and Peppol standards across NHS supply chains.

The mandate applies specifically to suppliers of medical devices and in-vitro diagnostic devices to the NHS. These suppliers are required to adopt GS1 standards for product and location coding and to exchange invoices electronically using Peppol access points. Compliance was phased between 2017 and 2019, with suppliers first required to send invoices via Peppol and later to embed GS1 identifiers for full traceability.

This is not a nationwide e-invoicing mandate but a sector-specific requirement, limited to NHS procurement processes.

FAQs

Who is affected by the UK’s e-invoicing mandate?

The requirement applies specifically to suppliers of medical devices and in-vitro diagnostic devices to the NHS. This includes both domestic and international companies supplying into the NHS. Other suppliers are not formally covered by the compliance timelines, though some NHS trusts may extend requirements more broadly.

What format must invoices follow?

Invoices must be exchanged via Peppol access points using the Peppol BIS billing 3.0 specification (UBL 2.1). From 2018-2019, invoices are also required to include GS1 identifiers - GTINs for products and GLNs for supplier and NHS locations.

What is the legal basis for the NHS e-invoicing mandate?

Unlike many countries, the UK’s NHS requirement is not anchored in tax law. Instead, it is enforced through the NHS standard contract and the NHS terms and conditions for the supply of goods and services, which require suppliers to adopt GS1 and Peppol standards.

Why did the NHS implement e-invoicing?

The main drivers were efficiency and patient safety. By using GS1 identifiers, products can be tracked across the supply chain and recalled quickly if necessary. At the same time, Peppol ensures interoperability, reduces invoice disputes, and lowers administrative costs.

Which documents are exchanged under the NHS eProcurement strategy?

Beyond invoices, the NHS requires electronic exchange of purchase orders and advance shipping notes via Peppol. Invoices form part of this wider purchase-to-pay process.

Country Specs

Mandate Status	Mandatory
Mandate Scope	B2G
Model Type	Interoperability / Post-Audit
Government Entity	Department of health and social care (DHSC)
Formats	UBL 2.1
Infrastructure / Platform	Peppol
E-signature Required	No
Key Deadlines	30 September 2017: Suppliers required to send invoices electronically via Peppol. 30 September 2018 - 31 March 2019: Invoices required to carry GS1 product (GTIN) and location (GLN) identifiers via Peppol.
AR Mandatory	From 30 September 2017 (suppliers must be able to send invoices via Peppol).
AP Mandatory	From 30 September 2017 (NHS access points must be able to receive invoices via Peppol).
Peppol Available	Yes
Domestic Transactions	Mandatory for NHS medical device suppliers only
Cross-border Transactions	Applies equally to international medical device suppliers if supplying into the NHS
Archiving Period	6 years
Archiving Abroad	Yes, provided records are readily available to UK authorities on request.

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