UK Electronic Sales Suppression and EPOS Standards 2026

HMRC is consulting on possible software standards for electronic point-of-sale (EPOS) and mobile point-of-sale (MPOS) systems to prevent electronic sales suppression, sometimes called till fraud. The consultation is aimed at businesses, EPOS developers, suppliers and other stakeholders in the retail and hospitality sectors.

The consultation does not create a new mandatory EPOS standard for every UK business today. It closed on 18 August 2026, and the official material says responses will inform future policy proposals. No final certification system, registration requirement, technical specification or implementation date is established by the consultation alone.

Businesses must still keep accurate records and report the tax that is due under current rules. See the UK record-keeping guide for the existing obligation, and do not confuse future software policy with the separate VAT registration rules in the VAT registration guide.

What is electronic sales suppression?

Electronic sales suppression is the manipulation of digital sales records to hide or reduce the value of transactions. It can involve unlawful software, hidden system functions or misuse of legitimate till features to remove, alter or understate sales before the business accounts and tax returns are prepared.

The tax consequences can extend beyond one tax. Lower recorded sales can affect VAT, Income Tax, Corporation Tax and other business reporting. A business must not treat an EPOS report as a safe substitute for a complete and accurate accounting record: the operator remains responsible for the information used in its returns.

HMRC already has compliance powers and legislation dealing with electronic sales suppression tools. The 2026 consultation is focused on prevention through software standards, rather than making the underlying conduct acceptable until a new standard arrives.

What is HMRC considering?

The consultation describes a possible package of measures for EPOS and MPOS systems, including:

• a complete and unalterable transaction log;
• encrypted links between transactions and adjustments;
• use of a standard data format such as SAF-T for relevant records;
• a register or certification approach for systems sold, transferred or used in the UK;
• mandatory information on receipts and system reports; and
• stronger expectations for suppliers to protect the integrity of their software.

These are consultation proposals. The document also recognises that implementation could happen over time and that updates to existing systems may be preferable to replacing every device. It does not publish a final technical standard that a business can certify against today.

Who may be affected?

The consultation is especially relevant to:

• retailers and hospitality businesses using EPOS or MPOS systems;
• takeaways and other businesses recording high volumes of customer transactions;
• software developers, hardware providers and resellers;
• accountants and tax advisers supporting businesses with digital sales records; and
• businesses integrating till, payment, inventory and accounting systems.

A business does not need to be VAT registered to have an accurate-record obligation. Likewise, being below the VAT threshold does not make suppressed sales acceptable. VAT registration, Income Tax or Corporation Tax liability and software controls are related but separate questions.

What should a business do now?

There is no need to replace a compliant system solely because the consultation was published. A proportionate preparation review should instead establish how sales records are created, adjusted, exported and reconciled.

Check whether:

• every sale, refund, void, discount and correction has an explainable audit trail;
• staff permissions prevent unauthorised changes to historic transactions;
• the till totals reconcile to payment-provider, bank and accounting records;
• the business can export records in a usable format when requested;
• the system supplier documents updates, access controls and data retention; and
• cash, card, delivery-platform and manually entered sales are included in the accounting process.

Keep evidence of the review and correct any known record gap promptly. If an accountant identifies an error in a tax return, follow the relevant correction process rather than altering historic till data to make the figures appear consistent.

Design a reliable sales-control chain

The useful question is not whether the till is cloud-based or whether it has a “lock” icon. It is whether a reviewer can trace a transaction from the customer order to the final accounting entry without unexplained gaps. Define the source record for each channel, including counter sales, online orders, delivery platforms, gift cards, deposits, tips, service charges and cash takings. Document which system creates the sale, which system records payment and which ledger receives the accounting entry.

Use role-based permissions and separate ordinary staff corrections from manager approvals. A void, refund, discount or price override should retain the original transaction reference, time, user, reason and authorisation. Offline trading should queue transactions for later synchronisation rather than allowing a user to overwrite the offline total. If a device is replaced, preserve the old export and the handover record. A new system should not make historic records disappear.

Reconcile at a frequency proportionate to the business. A small retailer may use a daily till-to-cash/card reconciliation; a multi-site hospitality group may need site-level daily controls, central exception reporting and a monthly general-ledger review. Investigate differences between EPOS totals, payment-provider settlements, bank credits, inventory movements and delivery-platform statements. A reconciliation that only compares the final bank deposit can miss cash sales, tips, refunds and timing differences.

Provider and procurement checks

Ask the EPOS provider how it handles transaction IDs, audit logs, corrections, data export, backups, encryption, user access, API integrations, offline mode and system retirement. Ask whether the provider can supply an immutable event history in a readable format and how long records remain available after the contract ends. These are sensible controls now, but they are not evidence that HMRC has certified the product or that it will meet a future statutory standard.

Record the version, configuration and integrations used on the date of each tax return. If the provider changes the data model or introduces a new discount feature, test the export and reconciliation before deployment. Include a right to obtain historical records in the contract and identify who owns the data if the supplier fails or the business changes provider. A cloud service can improve resilience, but the business remains responsible for reporting the figures it uses.

Incident response and tax corrections

If a user discovers an unexplained deletion, missing batch, duplicate receipt or suspicious adjustment, preserve the original logs and restrict further changes while the issue is investigated. Do not “repair” the history by entering an equal and opposite amount without recording the reason. Compare the EPOS export with bank, card, cash, inventory and delivery records, then quantify whether VAT, Income Tax or Corporation Tax returns may be affected.

Escalate suspected deliberate suppression to the accountant or tax adviser and follow HMRC disclosure or correction procedures where appropriate. A technical failure and deliberate evasion are not the same event, but both require an honest reconstruction of the sales record. Keep the incident timeline, access logs, backups, calculation of the adjustment and the decision-maker's approval. A clear response after discovery is stronger evidence than a system report that merely says “balanced”.

What the consultation status means for planning

The consultation closed on 18 August 2026. Until HMRC publishes a response, legislation or final technical material, businesses should treat certification, registration, standard data formats and mandatory receipt fields as possible future requirements rather than current legal tests. Procurement can still include those capabilities as sensible resilience requirements, but marketing copy should not call a product “HMRC compliant” without a specific legal basis.

Set a policy owner and review the consultation response when published. Maintain a short change log showing what was proposed, what was enacted and when the business updated its controls. This prevents a provisional proposal from being copied into staff training, customer contracts or software specifications as though it were already law.

What is not changing today?

The consultation does not replace current tax administration. Businesses should continue to:

• record all taxable sales accurately;
• retain business records for the required period;
• calculate VAT registration and return obligations under current rules;
• report trading profits or company profits using the applicable tax rules; and
• respond honestly to HMRC questions or compliance checks.

Do not wait for a future EPOS standard before fixing an incomplete sales ledger. Conversely, do not describe a current system as “HMRC approved” merely because it is widely used or connected to accounting software.

Frequently Asked Questions

This guide reflects HMRC and HM Treasury material available on 20 September 2026. Check the consultation response, any legislation and final HMRC technical guidance before relying on future EPOS or MPOS standards.

Official sources

• HMRC: Electronic Sales Suppression consultation
• HMRC: EPOS and MPOS software standards consultation document
• HMRC: Tax update 2026 summary
• HMRC: Electronic sales suppression — possession of tools
• GOV.UK: Record keeping for business