Making Tax Digital 2019: mandatory new regime for VAT

Making Tax Digital for VAT (MTDfV) brings mandatory new requirements from April 2019.

Making Tax Digital 2019: mandatory new regime for VAT

Making Tax Digital for VAT (MTDfV) brings mandatory new requirements from April 2019. But the change isn’t just about VAT. MTD affects the way that businesses keep records and the whole process of VAT return submission. This Briefing will help you plan for compliance.

New rules

MTDfV means that businesses must keep some records digitally. Coupled with this, VAT returns in future must be submitted to HMRC via an Application Programming Interface (API).
Submission can be from API-enabled spreadsheets, software or bridging software - software spanning the gap between business software and HMRC systems, permitting two-way digital communication and using MTD APIs. HMRC acknowledges there will be different ways to submit VAT returns under MTD, but the transfer of data to HMRC, from the mandatory digital records to the filing of the return, must be entirely digital. VAT Notice 700/22: Making Tax Digital for VAT spells out requirements in more detail.

Who is affected?

MTDfV affects any business with taxable turnover above the £85,000 registration threshold on 1 April 2019, regardless of its legal structure. Any business in MTDfV, whose turnover subsequently falls below the threshold, must stay in MTDfV, unless deregistering for VAT. Voluntarily registered businesses currently below the registration threshold can elect to join MTDfV but are not mandated to do so.
Any business exceeding the registration threshold after 1 April 2019 must also comply with MTDfV – and is given only 30 days to get digital. Voluntarily registered businesses need particular vigilance. Exceeding the threshold brings them into MTD immediately.


XYZ Ltd voluntarily registered for VAT in 2017. By 30 November 2019, cumulative sales in the previous 12 months exceed the mandatory VAT threshold. MTDfV rules apply to XYZ Ltd immediately – that is, from 1 December 2019. As it’s already VAT registered, there is no 30-day grace period.


Exemptions are limited to:

  1. businesses run by practising members of a religious society or order with beliefs incompatible with regulation requirements
  2. businesses subject to an insolvency procedure
  3. those satisfying HMRC that, for reasons of age, disability, remoteness of location or for any other reason, it is not reasonably practicable for them to use digital tools to keep business records or submit returns.

Exemption may apply even if someone is not currently exempt from VAT online filing.
If satisfied that keeping and retaining the specified information for each transaction is ‘likely to be impossible, impractical or unduly onerous,’ HMRC may vary the detail to be kept electronically.

Mandatory use of software

Under MTD, specified records will have to be kept digitally, using ‘functional compatible software.’ This means a ‘software program or set of compatible software programs which can connect to HMRC systems via an API’ which must be capable of:

  1. keeping specified records in digital form as required by the new rules
  2. preserving digital records in digital form for up to six years
  3. creating a VAT return from the digital records held in compatible software and submitting this data to HMRC digitally
  4. providing HMRC with VAT data on a voluntary basis
  5. receiving information from HMRC via the API platform.

Records to be kept digitally are specified in the VAT Notice. They include ‘designatory data’; the VAT account linking primary records and VAT return; and information about supplies made and received. Requirements are potentially more extensive than at present, for example in relation to supplies made. Here it will be necessary to record the different rates of VAT applicable. For supplies received, the amount of input tax to be claimed will be needed.
But MTD isn’t completely paper-free. It’s the actual recording of supplies made and received that must be digital. Where invoices and receipts aren’t held digitally, they should be kept in hard copy as usual for VAT purposes.

Timetable and submission process

For most businesses, the new rules apply from the start of the first VAT return period beginning on or after 1 April 2019. However, MTDfV for some ‘more complex’ businesses is now deferred until 1 October 2019. This deferral applies to: trusts; not for profit organisations not set up as companies; VAT divisions; VAT groups; public sector entities such as government departments and NHS Trusts, which have to provide additional information on their VAT return; local authorities; public corporations; traders based overseas; those required to make payments on account; annual accounting scheme users.
The first MTDfV submission depends on the quarterly return date.

Quarterly filing dates

Start of first return period subject to MTD

First quarter end within MTD for VAT

First MTD VAT return deadline (month plus 7 days)


1 April 2019

30 June 2019

7 August 2019


1 May 2019

31 July 2019

7 September 2019


1 June 2019

31 August 2019

7 October 2019

Under MTD, the VAT return is still a nine-box return. The key difference is that it will be populated by pulling data from the digital records. Returns will not be submitted by keying VAT return figures into the HMRC portal.

Further detail: VAT Notice 700/22

Software issues

The digital records required for MTD don’t have to be held in one place or one program. Businesses can keep digital records in a range of different compatible digital formats. The use of spreadsheets is allowed, in combination with add-on MTD software.
The question then arises as to how information will be transferred from one place to another. Basically, if that information is prescribed as part of what HMRC calls the ‘digital journey’ – the mandatory submission process – it has to be transferred via ‘digital link.’ The new VAT Notice explains this.

Digital links

A digital link is a transfer or exchange of digital data between software programs, products or applications. Where a set of software products is used, there must be digital links between them, and once data is entered into software, any further transfer or modification must be via digital link.
Manual data transfer isn’t allowed – say, noting details from invoices in one ledger, then using that handwritten information to update manually another part of the functional compatible software. Copying by hand or manual transposition of data between two or more pieces of software is not permitted, and crucially, cut and paste, or copy and paste isn’t acceptable in the long term. The VAT Notice outlines acceptable digital links, including:

  1. linked cells in spreadsheets
  2. emailing a spreadsheet with digital records to an agent for the agent to import data into software to make a calculation, such as a partial exemption calculation
  3. transferring digital records onto portable devices (pen drive, memory stick) and giving these to an agent
  4. XML, CSV import and export, download and upload of files
  5. API transfer.

Transition: soft landing penalty period

For VAT return periods beginning between 1 April 2019 and 31 March 2020, penalties won’t be charged if businesses don’t have digital links between software programs. This means cut and paste is briefly acceptable while businesses update their systems. However, from 2020, HMRC will penalise non-compliance. The transfer of VAT return data to bridging software to make submissions to HMRC must always be digital, and is excluded from the soft landing provisions.

Adjustments and special cases

At present, adjustments are often needed before VAT returns are submitted: such as capital goods scheme adjustment calculations, the fuel scale charge and partial exemption calculations. Under MTD, these can be calculated outside the digital records and the total then recorded digitally.
MTD rules recognise a variety of special cases, including retail scheme users, who will be able to record daily gross takings digitally, rather than details of each supply. Other provisions deal with:

  1. recording mixed rate supplies with a single price
  2. invoices for multiple supplies
  3. employee expenses
  4. reverse charge supplies
  5. intra-group supplies for a VAT group
  6. supplies made by third party agents.

Software providers

HMRC is not providing software. It is working with software providers to get products on the market by the MTD start date, and lists recognised products on the site as they become ready. The current list can be found at If you already use accounting software and your supplier is not on this list, ask if and when they will upgrade products to be MTD-compatible.

Recommended action

We advise considering the impact of MTDfV now. Any business not using digital accounting records will need to do so as soon as possible, and spreadsheet users may need bridging software or API-enabled spreadsheets to submit VAT returns. If you use a combination of different software systems and spreadsheets, decide how to have digital links in place by 2020, and how returns will be filed from 2019. Some businesses will be eligible to join the MTDfV pilot run by HMRC, giving the opportunity for a dry run before mandation. However, the pilot is not yet open to every type of business, and the timetable is still evolving.

We are on hand to answer any questions your business may have about this transition.