London, United Kingdom — HMRC has announced the criteria for the Third Phase of the Making Tax Digital (MTD) e-Invoicing rollout. This phase targets taxpayers whose revenues subject to VAT exceeded £250 million during 2023 or 2024.
Core Requirements
Affected taxpayers must integrate their e-invoicing solutions directly with the HMRC MTD platform starting from October 1, 2025. Failure to integrate by this deadline will result in financial penalties under Schedule 55 of the Finance Act 2009.
Technical Compliance
- Solutions must be able to generate unique transaction reference numbers (UTRNs) for invoices.
- Digital signing and tamper-proof audit trail requirements are enforced.
- Prohibition of uncontrolled access, record tampering, or duplicate invoice sequences.
Businesses falling into this revenue bracket should immediately audit their ERP systems (SAP, Oracle, Microsoft Dynamics) to ensure specialised middleware is installed for the HMRC API communication layer.