7 min read2026-27Reviewed Apr 2026

Making Tax Digital for VAT: What Directors Need to Know

MTD for VAT has been mandatory for all VAT-registered businesses since April 2022. Here's what it requires and how to stay compliant.

Reviewed by D. Cann · Principal, Apex Assets Group
  • MTD for VAT: mandatory for all VAT-registered businesses since April 2022
  • Manual portal entry is not permitted — returns must come from MTD-compatible software
  • Spreadsheets are allowed only with bridging software connecting to HMRC's API
  • Digital records required: date, supplier/customer, net amount, VAT amount for each transaction
  • Penalty regime: points-based — points accumulate for late submissions, triggering financial penalties

MTD for VAT: what is required

Since April 2022, every VAT-registered business in the UK must comply with Making Tax Digital for VAT. There are two core obligations:

  1. Keep digital VAT records — the key transaction data for every sale and purchase must be recorded digitally
  2. Submit VAT returns digitally via MTD-compatible software — not manually via HMRC's online VAT portal

These requirements apply regardless of business size or VAT scheme (standard rate, Flat Rate Scheme, Annual Accounting, Cash Accounting — all are within MTD for VAT).

What counts as digital records?

HMRC requires digital records of the following for each VAT transaction:

Data field requiredFor sales (output tax)For purchases (input tax)
Date of supplyYesYes
Supplier or customer nameCustomer (if VAT invoice issued)Supplier
Net value (ex-VAT)YesYes
VAT amountYesYes
VAT rate appliedYes (20%, 5%, or 0%)Yes

You do not need to scan and upload images of every invoice. The data fields above, entered into your MTD software at or near the time of the transaction, satisfy the digital records requirement. Paper originals can be retained physically.

How MTD-compatible software works

MTD-compatible software connects directly to HMRC's API (Application Programming Interface). When you are ready to file your VAT return, the software generates the 9-box return figures from your digital records and submits them electronically to HMRC via the API. You do not type numbers into HMRC's website.

Three categories of compliant software:

Software typeHow it worksExamples
Full accounting package (native MTD)Records transactions, generates VAT return, submits directlyFreeAgent, Xero, QuickBooks, Sage
Dedicated VAT softwareSpecifically designed for VAT — enter data and submitVAT Bridge, various HMRC-listed tools
Bridging softwareTakes data from your spreadsheet and submits it via APITax Blaster, Absolute, DataDear

Bridging software: staying with spreadsheets

If you maintain VAT records in Excel or Google Sheets and do not want to switch to accounting software, bridging software is a compliant option. It connects to your spreadsheet, reads the summary VAT return figures (the 9 boxes), and submits them to HMRC's API.

Requirements for bridging software compliance:

  • The data in your spreadsheet must be digitally linked — no re-keying of figures from one cell to another manually (copy and paste is not acceptable; formula links are)
  • The bridging software must be on HMRC's approved list
  • The submission must go via the API — not typed into HMRC's portal

The digital link rule: If you use multiple spreadsheets or copy figures between cells, the connections must be formula-based (e.g., =Sheet1!A1), not manually typed. "Digital linking" ensures there is an unbroken electronic trail from transaction data to the VAT return figures. This rule exists specifically to prevent errors introduced by manual re-entry.

The VAT account

MTD regulations require businesses to maintain a VAT account as part of their digital records. The VAT account is a running record that shows, for each VAT period:

  • Total output VAT (VAT charged on sales)
  • Total input VAT (VAT reclaimed on purchases)
  • Adjustments (corrections from prior periods, Flat Rate Scheme adjustments, etc.)
  • Net VAT payable or reclaimable

Most accounting software maintains this automatically as you enter transactions — it is not a separate document you need to create manually.

Penalty regime for MTD for VAT non-compliance

HMRC uses a points-based penalty system for late submissions, introduced in January 2023:

EventConsequence
Each late VAT return submissionOne penalty point added to your account
Quarterly filers reach 4 points£200 financial penalty charged
Each subsequent late submission at thresholdAdditional £200 penalty per late submission
Points reductionAfter a sustained period of compliance and all returns up to date

Separate from late-submission penalties, HMRC also charges late-payment interest and penalties for unpaid VAT — these are independent of the submission penalty points system.

What MTD for VAT does NOT require

Common misconceptions:

  • You do not need to send invoices electronically or receive e-invoices
  • You do not need to scan every receipt — only digital transaction data is required
  • You do not need to use cloud accounting — desktop software with an MTD API connection is acceptable
  • You do not need to change your VAT scheme — Flat Rate, Annual Accounting, and Cash Accounting all work within MTD

Voluntary VAT registration and MTD

If you have voluntarily registered for VAT (below the £90,000 threshold), MTD for VAT still applies to you. Voluntary registration does not exempt you from digital record-keeping and MTD submission requirements. This catches some smaller businesses that registered voluntarily for commercial reasons without realising the compliance implications.

Deregistering from VAT

If your taxable turnover falls below the deregistration threshold (£88,000) and you choose to deregister, you exit the MTD for VAT regime. After deregistration you revert to no VAT filing obligations. Note: deregistration can affect your VAT recovery on costs, so model the impact before deregistering.

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Frequently asked questions

Can I still use a spreadsheet for VAT?
Yes — but only with bridging software that submits the data digitally to HMRC via the API. A spreadsheet alone is not MTD-compliant. The data within the spreadsheet must be digitally linked (formula connections, not manual re-keying) and the bridging software must be on HMRC's approved list.
What if I make an error on a VAT return?
Small errors (net VAT error below £10,000, or below 1% of Box 6 turnover up to a maximum of £50,000) can be corrected on the next VAT return — add or subtract the correction in Box 1 or Box 4. Larger errors require a voluntary disclosure on form VAT652. Disclosing proactively before HMRC discovers the error significantly reduces any penalties.
What if my accounting software does not connect to HMRC?
All major accounting packages (FreeAgent, Xero, QuickBooks, Sage) are MTD for VAT compliant. If your software is older or specialist, check HMRC's approved software list. If it is not on the list, switch to compliant software or add bridging software. Using non-compliant software makes every VAT submission technically non-compliant, even if figures are correct.
Does MTD for VAT apply if I use the Flat Rate Scheme?
Yes — the Flat Rate Scheme does not exempt you from MTD for VAT. You still must keep digital records and submit via MTD-compatible software. The Box 1 calculation differs (FRS % × VAT-inclusive turnover), but the submission mechanism is identical.
I missed signing up for MTD for VAT — what should I do?
You are already technically in breach if you have been filing manually since April 2022. Move to MTD-compatible software and begin filing correctly immediately. HMRC has been relatively lenient for businesses that come into compliance proactively — contact HMRC to explain the situation and regularise your position before an inspection or penalty notice arrives.

Important: This guide is for general information only and does not constitute tax or legal advice. Tax rules change — always verify current rates and thresholds with HMRC or a qualified accountant before making decisions.