What Is Making Tax Digital for VAT?
Making Tax Digital (MTD) for VAT is HMRC’s requirement to keep digital records and submit VAT returns using compatible software. It is not optional. If your agency is VAT-registered, you must comply.
The old method of logging into the HMRC portal and typing in nine boxes of numbers manually is gone. From April 2022, MTD for VAT became mandatory for all VAT-registered businesses, regardless of turnover. That includes every agency from a sole trader web designer in Manchester Northern Quarter to a 50-person digital agency in Bristol Harbourside.
There are no exceptions for size, sector, or turnover once you are VAT-registered. If you have a VAT number, you need MTD-compatible software.
Why HMRC Introduced MTD for VAT
HMRC estimates that the UK tax gap, the difference between tax owed and tax paid, is around £35 billion per year. A significant portion comes from avoidable errors in VAT returns. Manual data entry, spreadsheet errors, and transposition mistakes all add up.
MTD aims to reduce those errors by forcing a digital link between your accounting records and your VAT submission. No more copying numbers from one spreadsheet to another. No more typing nine boxes of figures into a web portal by hand.
For agencies, the practical effect is straightforward. Your accounting software, Xero, QuickBooks, FreeAgent, Sage, or an MTD-bridging tool, sends the VAT return directly to HMRC. You review it, approve it, and submit it from within the software.
Does MTD for VAT Apply to Your Agency?
Yes, if you are VAT-registered. Here is the full breakdown.
- Mandatory for all VAT-registered businesses since April 2022. No turnover threshold applies once you are registered.
- Applies to both standard VAT accounting and flat rate VAT. If you use the flat rate scheme, you still need MTD-compatible software.
- Applies to annual accounting and cash accounting schemes. The scheme you use for VAT does not exempt you from MTD.
- Applies to partial exemption and the VAT margin scheme. If your agency buys and sells used goods or deals with mixed supplies, MTD still applies.
If you are not yet VAT-registered but your turnover is approaching the £90,000 threshold, you will need to register. At that point, MTD compliance becomes mandatory from your first VAT return.
What You Need to Do: The Practical Steps
Step 1: Check Your Software
Your accounting software must be MTD-compatible. Most modern cloud accounting platforms already are. Here is the status for the most common agency tools.
- Xero: MTD-compatible. Submits VAT returns directly to HMRC. You do not need a separate bridging tool.
- QuickBooks: MTD-compatible. Same process as Xero.
- FreeAgent: MTD-compatible. Popular with agencies using FreeAgent for full accounting.
- Sage: MTD-compatible if you are on a current version. Older desktop versions may need upgrading or a bridging tool.
- Excel or Google Sheets: Not MTD-compatible on their own. You need a bridging tool like Dext or a direct API connection to HMRC.
If you are still using a desktop accounting package from 2019, you almost certainly need to upgrade. Check with your accountant before your next VAT return is due.
Step 2: Set Up Digital Links
MTD requires a digital link between every stage of your VAT data flow. That means:
- Your source data (sales invoices, purchase invoices, bank transactions) must be digital.
- Your calculations (VAT totals, partial exemption calculations) must be performed in software.
- Your submission to HMRC must come from that software.
The most common compliance failure for agencies is what HMRC calls "cut and paste", manually copying numbers from one system to another. If you export a CSV from your time tracking tool, paste it into a spreadsheet, adjust the VAT, then type the totals into your accounting software, you have broken the digital link.
Fix this by using integrations. Most agency tools, Harvest, Toggl, Float, Dext, connect directly to Xero or QuickBooks. Set those integrations up properly, and your digital link is intact.
Step 3: Authorise Your Software
You must authorise your software to send VAT returns to HMRC on your behalf. This is a one-time setup per software.
In Xero, go to the VAT section, click "Set up MTD," and follow the prompts to sign into your HMRC Government Gateway account. The same process applies in QuickBooks, FreeAgent, and Sage.
If you use an agent (your accountant), they can handle this authorisation for you. Many agencies prefer to have their accountant manage the MTD submission directly. That is fine, just make sure the authorisation is in place before your next return is due.
Step 4: File Your First MTD Return
Once your software is set up and authorised, your next VAT return will be filed through MTD. The process is:
- Your accounting software calculates the VAT figures from your digital records.
- You review the figures within the software.
- You approve the return.
- The software submits it to HMRC.
You no longer log into the HMRC portal to file VAT. If you do, you will get an error message telling you to use MTD-compatible software.
What Happens If You Don't Comply?
HMRC has been pragmatic about MTD enforcement, but that is changing. From 2024, HMRC began issuing penalties for non-compliance more consistently.
The penalty structure for late VAT returns under MTD is:
- First late submission: No penalty if you file within 15 days of the due date. A £200 penalty if you file after 15 days.
- Second late submission: £200 penalty regardless of how late.
- Subsequent late submissions: £200 per return, plus a further £200 if you are more than 15 days late.
These penalties apply to each VAT return, not each quarter. If you miss four quarterly returns, you could face £800 in penalties before interest.
Separately, if your records are not digital or your software is not MTD-compatible, HMRC can issue a penalty for failing to keep proper records. That penalty is up to £3,000 per failure.
For agencies, the practical risk is lower if you are already using cloud accounting software. But if you are still on a desktop package or using spreadsheets, you are exposed.

