UK Confirms Mandatory EPOS and MPOS Software Standards Following HMRC Consultation

The UK government has confirmed that mandatory software standards will be introduced for electronic and mobile point-of-sale systems to combat till fraud. HMRC published its consultation outcome on October 28, 2026, with detailed technical proposals expected in summer 2027.

On October 28, 2026, HM Revenue & Customs (HMRC) published the summary of responses to its consultation on Electronic Sales Suppression (ESS), confirming the UK Government's decision to introduce mandatory software standards for Electronic Point of Sale (EPOS) and Mobile Point of Sale (MPOS) systems.

The consultation began on June 23, 2026, remained open for eight weeks and officially closed on August 18, 2026. During this period, HMRC invited retailers, POS software developers, manufacturers, payment providers, industry associations, and fiscalization specialists to provide feedback on the proposed measures.

The government has now confirmed its intention to proceed with mandatory standards, following generally positive feedback from industry representatives.

However, the standards are not yet legally applicable. Their technical requirements, legislative framework and implementation timetable will be developed through further consultations, with the next technical consultation planned for summer 2027.

HMRC received feedback from 21 stakeholders, including 17 written responses and contributions from four additional participants through roundtable discussions.

The overall response was strongly in favor of introducing software standards:

5 respondents were strongly supportive.
13 supported the proposal with certain conditions.
1 expressed mixed views.
1 expressed concerns.
1 opposed the proposal.
Respondents generally agreed that additional controls are necessary to prevent ESS, a form of tax fraud involving the manipulation, deletion or concealment of electronic sales records to reduce reported turnover and tax liabilities.

However, the industry also emphasized that the new requirements must be proportionate, technologically neutral and compatible with existing retail business processes.

The feedback particularly highlighted the potential implementation costs for smaller software providers and retailers, the need for clear technical specifications and the importance of allowing existing POS systems to be upgraded rather than requiring their replacement.

Although the government has decided to introduce mandatory standards, HMRC has not yet determined the final technical model.

The consultation outcome identifies several areas that will shape the future requirements.

Transaction protection and audit trails

Respondents broadly supported protecting electronic sales records against undetectable manipulation or deletion. Possible technical approaches include digital signatures, hashing and cryptographic transaction chaining.

However, further clarification is necessary regarding when transactions must become protected, particularly for unfinished transactions, refunds, corrections, cancellations and voids.

Standardized sales data formats

There was broad support for introducing standardized data export requirements, potentially using the Standard Audit File for Tax (SAF-T).

Respondents generally preferred systems to generate standardized files when required rather than having to store all operational information in that format.

HMRC has not yet confirmed SAF-T as the mandatory standard.

Certification and registration

The consultation also examined potential certification and registration arrangements for EPOS and MPOS systems.

Some respondents favored manufacturer self-certification, while others supported independent assessment or a combination of both.

The government will further evaluate these approaches, including the responsibilities of software providers, distributors and retailers.

Receipt requirements and compliance checks

Possible requirements concerning receipt information, transaction references, and QR codes were also discussed.

However, many respondents opposed automatically issuing receipts for every transaction because of additional operational costs and environmental considerations.

HMRC will continue examining whether receipts should be generated, offered, or automatically issued, and how standardized transaction records could support simpler compliance checks.

Importantly, none of these individual technical measures has yet been confirmed as a final legal obligation.

Fiscal Solutions participated in the consultation.

Fiscal Solutions was among the industry stakeholders contributing to the HMRC consultation, providing comments based on its experience with international fiscalization regulations, POS compliance requirements and electronic transaction controls.

According to Fiscal Solutions' direct communication with HMRC, the authority acknowledged and appreciated the company's contributions to the consultation process.

Fiscal Solutions is also maintaining communication with HMRC regarding future developments and the next stages of the initiative.

This participation allows Fiscal Solutions to contribute practical knowledge from different fiscalization systems and help address the technical and operational challenges associated with introducing mandatory POS software standards.

The company's involvement is particularly relevant as HMRC intends to continue working directly with software providers, businesses and technical specialists before publishing its detailed implementation proposals.

The government announced its decision to introduce mandatory EPOS and MPOS software standards as part of Budget 2026.

HMRC will now continue technical discussions with industry representatives to determine the precise requirements, including data protection, software certification, registration, transaction reporting and implementation arrangements.

A further technical consultation is expected in summer 2027, presenting detailed implementation proposals.

The government intends to introduce legislation through a future finance bill. No mandatory implementation date has yet been established, and businesses are not currently required to modify their POS systems under these proposed standards.

Impact on affected businesses

The decision indicates that EPOS and MPOS software used by UK businesses will eventually need to comply with mandatory standards for protecting electronic sales records.

POS manufacturers and software providers should begin reviewing their existing transaction recording, audit trail, data export and security capabilities. However, specific technical changes should not be treated as mandatory until the final requirements are published.

Retailers, retail chains, hospitality businesses, and other POS users should monitor the upcoming technical consultation and assess whether their existing systems can support future compliance updates.

What should businesses do?

The immediate priority is preparation, not mandatory implementation. The next development to monitor is HMRC's technical consultation in summer 2027, which should clarify the proposed system requirements, responsibilities, and implementation approach.

The government's decision represents an important change in the UK's approach to retail transaction controls. Rather than relying exclusively on investigations and penalties for electronic sales suppression, the UK intends to introduce preventive software requirements that make sales manipulation more difficult.

We consider the industry's feedback particularly relevant because technical security requirements must not interfere with normal retail operations or create unnecessary implementation costs.

Experience from other fiscalization jurisdictions shows that clear technical specifications, realistic transition periods and close cooperation with software providers are essential for implementing such systems successfully.

Fiscal Solutions' participation and continued communication with HMRC are valuable opportunities to contribute international experience to the development of a practical UK framework.

The consultation income can be found on the official website of the UK’s HMRC: link

Ivana Picajkic, Medior Legal Consultant at Fiscal Solutions

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