Small Business Accountants

Managing Invoices Whilst Waiting for VAT Registration

Once you apply for VAT registration, HMRC can take up to 30 working days to issue your VAT number. During that time you cannot show VAT on your invoices. The practical workaround is to charge VAT-inclusive prices and reissue proper VAT invoices as soon as your number arrives. Good record-keeping throughout protects you if your effective registration date is backdated.

Managing invoices whilst waiting for VAT registration - GoForma Tax Guides | UK Accountants & Tax Advisors
This article is part of our Small Business Accountants guide — your essential resource for running a small business.

Key takeaways

  • HMRC can take up to 30 working days to issue a VAT registration number after you apply, and in some cases processing takes longer depending on their workload and any additional checks needed.
  • You cannot issue a VAT invoice or show VAT as a separate line item until you have received your official VAT registration number from HMRC.
  • The legal workaround is to charge VAT-inclusive prices during the waiting period, for example charging £120 instead of showing £100 plus £20 VAT as separate amounts.
  • Once your VAT number arrives you must reissue proper VAT invoices for any supplies made from your effective date of registration, as VAT-registered customers need them to reclaim input VAT.
  • Keep records of every invoice issued during the waiting period, because your effective registration date may be backdated and VAT will be due on all taxable supplies from that date.

During the time between submitting your application to register for VAT and waiting for your VAT registration number, you won’t be able to issue VAT invoices or to show VAT as a line item on your invoices.

To get around this issue, you can include VAT in the invoice total amount—without indicating VAT as a line item or showing it in your invoice. For instance, if you’re charging a client £100 for a service rendered, you’ll invoice the client for £120 to account for the standard rate VAT of 20%.

When you’ve received your VAT registration number, you can then reissue the invoice for £100 (and include £20 VAT as a line item).

Frequently asked questions

Can I issue invoices while waiting for my VAT number?

Yes, you can issue invoices while waiting but you cannot show VAT as a separate line item or describe them as VAT invoices. Instead, charge a VAT-inclusive total. Once your VAT number arrives, reissue those invoices in the correct VAT invoice format showing the VAT amount, your VAT number, the tax point date and all other required fields. Your customers who are VAT-registered will need the reissued invoices to reclaim their input VAT.

How long does HMRC take to issue a VAT number?

HMRC states that online VAT registration can take up to 30 working days to process. In practice, processing times vary depending on HMRC workload and whether additional verification checks are needed. There is no way to pay to expedite the process. You can track the status of your application through your Government Gateway account. If 30 working days pass with no response, contact HMRC directly to chase the application.

What is VAT-inclusive pricing and how does it work?

VAT-inclusive pricing means your invoice total already contains the VAT element without displaying it as a separate line. For example, if your standard price is £100 and the VAT rate is 20%, you charge the customer £120 as a single amount. The invoice does not show a VAT breakdown. Once your VAT number is confirmed you reissue the invoice with the proper VAT split, and the customer pays nothing additional because the VAT was already included in what they paid.

What is an effective date of VAT registration?

The effective date is the date from which HMRC treats you as VAT-registered. For mandatory registration it is typically the first day of the second month after you exceeded the £90,000 threshold. For voluntary registration HMRC agrees a date with you. VAT is due on all taxable supplies made on or after that effective date, even if your VAT number arrived weeks later. You must account for VAT from the effective date, not the date the number was issued.

Can my effective registration date be backdated?

Yes. If you applied for voluntary registration and requested an earlier start date, or if HMRC determines you should have registered sooner, your effective date can be set in the past. This means VAT is owed on sales made before your number arrived. Keep clear records of all invoices issued during the waiting period so you can identify which supplies fall within the backdated period and account for the output VAT correctly on your first VAT return.

When can I start reclaiming input VAT on purchases?

You can reclaim input VAT on purchases made for business use from your effective date of registration. For goods held on that date, you may reclaim input VAT going back up to four years. For services, you can reclaim input VAT on those received within the six months before your effective date. Keep all purchase invoices as HMRC may request them during a compliance check.

What must a proper VAT invoice include?

A full VAT invoice must include your business name and address, your VAT registration number, a unique sequential invoice number, the invoice date, the tax point date, the customer name and address, a description of the goods or services supplied, the quantity and unit price, the VAT rate applied, the net amount, the VAT amount, and the VAT-inclusive total. Invoices under £250 inclusive of VAT may use a simplified VAT invoice format, but must still show your VAT number.

What happens if I show VAT on an invoice before I have a VAT number?

Showing VAT on an invoice before you have a VAT number is not permitted. HMRC can treat the VAT you charged as a debt even though you are not yet registered, so you would owe the amount without any input VAT offset. Your customer cannot use the invoice to reclaim input VAT because it lacks a valid VAT number. Wait until your number is confirmed before issuing any document described as a VAT invoice.

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