PEPPOL IN EUROPE
E-invoicing in the United Kingdom
The United Kingdom does not have a general requirement for electronic invoicing. However, within the National Health Service (NHS), there are sector-specific requirements for electronic invoicing and digital data exchange.
These requirements are part of the NHS’s e-procurement strategy, which was introduced in 2014. The strategy aims to modernize procurement processes, increase efficiency, and improve patient safety. To this end, GS1 and Peppol standards, among others, are applied within the NHS supply chain.
The requirements apply specifically to suppliers of medical devices and in vitro diagnostics to the NHS. They must use GS1 standards for the identification of products and locations and exchange electronic documents via Peppol.
The implementation took place in phases between 2017 and 2019. Suppliers first had to be able to send electronic invoices via Peppol. Subsequently, GS1 identification codes were introduced to enable full traceability of products and deliveries.
These requirements do not apply to all businesses in the United Kingdom, but specifically to suppliers within the NHS supply chain.
Who is subject to the e-invoicing requirement?
The requirements primarily apply to suppliers of medical devices and in vitro diagnostic devices to the NHS. This includes both U.K. and international suppliers.
Other suppliers are not automatically subject to the same requirements. However, individual NHS organizations or NHS Trusts may include the requirements in their own procurement terms and conditions.
What format must electronic invoices follow?
Invoices are exchanged via Peppol Access Points in accordance with the Peppol BIS Billing 3.0 specification, based on UBL 2.1.
In addition, invoices and other electronic documents must contain relevant GS1 identification codes. These include GTINs for identifying products and GLNs for suppliers and NHS locations.
What is the legal basis for the NHS requirement?
The requirement is not based on U.K. tax legislation. It stems from the NHS’s standard contracts and general terms and conditions for the supply of goods and services.
Through these contractual terms, suppliers are required to apply the prescribed GS1 and Peppol standards.
Which documents are exchanged via Peppol?
The NHS incorporates Peppol into the broader purchase-to-pay process not only for electronic invoices. Other documents can also be exchanged electronically, including:
- Purchase orders
- Advanced Shipping Notices
- Electronic invoices
As a result, the NHS supports a fully digital exchange of documents throughout the procurement and delivery process.
