ACCA welcomes the opportunity to respond to HMRC on Promoting electronic invoicing across UK businesses and the public sector. As a chartered professional body, we operate in the public interest; our members operate across a broad range of sectors, public and private, from micro businesses to large firms. Many of our members operating within organisations, while many work in practice with a broad range of clients.

ACCA continues to advocate for a simpler, more efficient and responsive tax system. However, with so much investment already having been made by software providers, taxpayers and all key stakeholders in Making Tax Digital (MTD), we would be concerned that the implementation of e-invoicing could potentially dilute already finite resources and lead to delays. We would encourage a cautious approach when considering the capacity HMRC would have to implement new developments such as e-invoicing while HMRC reforms and areas such as MTD are at the early stages of phased implementation. 

ACCA makes following suggestions:

• ACCA would favour a voluntary decentralised implementation of a 4-corner model for a number of reasons, including the flexibility and independence this would allow.
• Such a voluntary system of e-invoicing designed to encourage business adoption to realise key business benefits. Cost benefit analysis will remain crucial as well as considering how e-invoicing can best work for business in practice.
• In addition to a voluntary approach, ACCA would encourage government to consider a phased implementation to allow capability and capacity to grow and to learn lessons from those entities most equipped to undertake this at the outset.
• On standards, we would encourage HMRC to consider the suitability for business when considering the data that a standard should include as well as the structure of information. We would also encourage HMRC to look at existing standards from jurisdictions where e-invoicing is already present and carefully consider any alterations or amendments to those standards, and the cost benefit associated with such alterations or amendments.
• ACCA believes that government should maintain focus on ensuring that MTD achieves its objectives before the rollout of another scheme.

Please download the attachment found on this page to read our full response.